FFIEC
Secure FFIEC compliance with Codekeeper escrow
Ensure business continuity and manage your vendor risks with Codekeeper’s state-of-the-art software escrow solutions for financial institutions.
Who needs to comply with the FFIEC?
If you operate in the US financial sector, FFIEC guidelines likely apply to you. This includes:
Banks
Credit unions
Savings associations
Financial services providers
We see the challenges you face:
Complex vendor risk management requirements
Ongoing third-party service disruptions
Mounting pressure to meet FFIEC expectations
Uncertainty around business continuity documentation and audit readiness
With years of experience in risk mitigation, regulatory alignment, and software protection, we help organizations like yours stay secure — and audit-ready.
We don’t just provide tools. We guide you every step of the way.
Software Escrow
Protection scope: On-premises software
Secures critical software assets used in core operations.
Meets FFIEC expectations for software recovery and vendor oversight
Guarantees access to mission-critical systems
Documents fallback provisions for regulators
Enforces rights through legal agreements
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SAAS escrow
Protection scope: Cloud-based and SaaS apps
Protects hosted platforms that power daily operations.
Addresses FFIEC’s focus on cloud service oversight
Ensures SaaS access and recoverability
Reinforces institutional control over cloud assets
Keeps records ready for regulatory audits
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continuity escrow
Protection scope: SaaS & vendor-dependent services
Maintains continuity when third-party or infrastructure providers fail.
Reduces disruption risks such as data loss
Documents continuity actions for examiners
Manages fourth-party service dependencies
Demonstrates operational readiness and governance support
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Verification
Protection scope: All escrowed assets
Validates that escrow deposits are complete and usable.
Offers proof of viable recovery paths
Confirms recovery time objectives (RTOs)
Supplies regulator-ready test documentation
Increases examiner confidence in your contingency plans
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Get FFIEC compliant in 4 simple steps
FFIEC guidelines require you to maintain access to critical software if vendors fail. Here's how to fulfill this requirement quickly:
1. Schedule your compliance call
We'll identify the systems that need FFIEC protection.
2. Choose your protection level
Basic escrow or full verification — we'll help you pick the right fit.
3. We do the heavy lifting
From vendor onboarding to legal agreements — handled for you.
4. Receive your Resilience Certificate
Proof for regulators that your critical software is compliant.
One call. One solution. Complete software continuity compliance for FFIEC.
Book a free demo
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July 19, 2021
Proposed interagency guidance published: Federal Reserve, FDIC, and OCC outline enhanced third-party risk management expectations, including software access/recovery, third-party oversight, and continuity planning. -
June 7, 2023
Final interagency guidance issued by FDIC, OCC & Federal Reserve: Institutions must establish clear oversight of escrow arrangements, including annual validation, updates, and recovery provisions -
From 2023 onwards
Compliance expectations in force: Examiners now expect institutions to have robust software escrow programs, verification, and continuity measures in place to meet FFIEC resilience standards.
July 19, 2021
Proposed interagency guidance published: Federal Reserve, FDIC, and OCC outline enhanced third-party risk management expectations, including software access/recovery, third-party oversight, and continuity planning.
June 7, 2023
Final interagency guidance issued by FDIC, OCC & Federal Reserve: Institutions must establish clear oversight of escrow arrangements, including annual validation, updates, and recovery provisions
From 2023 onwards
Compliance expectations in force: Examiners now expect institutions to have robust software escrow programs, verification, and continuity measures in place to meet FFIEC resilience standards.
What's at risk if you're not FFIEC compliant
Failing to meet FFIEC expectations exposes financial institutions to:
Regulatory penalties and citations
FFIEC-examining agencies can issue formal enforcement actions for gaps in vendor or software resilience programs.
Heavier audit and examination scrutiny
Examiners may dive deeper into third-party risk management and require frequent or more intensive reviews.
Operational breakdown risks
Without tested escrow and recovery procedures, critical software vulnerabilities could lead to system disruptions.
Reputational harm
Potential findings or failures tied to vendor risk and continuity may erode trust with customers and stakeholders.
Impacts to business continuity
Vendor failures without fallback protections could disrupt essential services — jeopardizing both operations and compliance.
E-BOOK
FFIEC Compliance: Your Complete Continuity & Risk Management Guide
Fill in the form below to get expert guidance on meeting FFIEC’s third-party risk and operational continuity expectations.
*E-book available only in English
Get your free FFIEC compliance guide
How you benefit from FFIEC compliance
Avoid regulatory penalties
Meet FFIEC expectations to prevent audit findings, enforcement actions, and increased regulatory scrutiny that could significantly disrupt your operations and damage your institution’s financial position.
Maintain operational continuity
Ensure critical systems and services stay online — even when key software vendors experience outages or disruptions. FFIEC compliance strengthens your ability to recover quickly and minimize downtime.
Build examiner and stakeholder trust
Demonstrate to auditors, customers, and partners that your organization takes risk management and operational resilience seriously. FFIEC compliance signals institutional maturity and regulatory readiness.
Strengthen board-level governance
Equip leadership with clear oversight and documentation of third-party risk controls. FFIEC-aligned continuity planning enhances your governance framework and supports strategic decision-making.
Prove you’re FFIEC compliant — before the next audit
Our specialists will show you exactly how software escrow supports your regulatory, continuity, and risk management goals — without unnecessary complexity.
Personalized guidance
Clear next steps
No jargon, no pressure