| EU | USA | Singapore |
Overview of regulatory/supervisory bodies in the area of SCRM | Banking Regulation by EBA; Banking supervision by ECB/national supervisor | National banking authority & each state’s banking authority, e.g. FED and NYSDFS | Regulatory body and supervisory body unified by the MAS |
Regulatory/supervisory system in the area of SCRM | Two independent functions | Not completely independent functions | Only one function |
History of regulatory/supervisory system | World Financial Crisis in 2008 → Single Supervisory Mechanism of the EU | World Financial Crisis of 2008 → overregulation by new regulation & standards | Based on Asian approach & oriented on Western world |
Guidelines issued in the area of SCRM and Outsourcing | Several regulations to follow | Several guidelines by multiple regulators & standard-setters | Strict and clear approach; Single point of truth |
Application of guidelines in the field of Outsourcing | Self-assessment of each bank; Principle oriented nature | Self-assessment of each bank; Principle oriented nature | Self-assessment of each bank; Principle-oriented nature |
Definition of “Outsourcing” and “service provider” | Outsourcing = process, service or activity that would be undertaken by the institution itself; service provider = third-party entity | Outsourcing = arrangements are limited to those listed in FED 13.19 service provider = third-party entity | Outsourcing = widest definition; even including intra-group arrangements service provider = including all entities that provide a service |
Existence of standards | Standards exist | Standards are integral part of the regulatory program | Not required if not included in guidelines by MAS |