● Incident Reports (IRs) and narratives generated in connection with loan reviews
- Date
- 2023-03-15
Summary
Exhibit 3, filed March 15, 2023 as Doc 685-3 in Case 22-10951-CTG, is a four-page schedule headed KServicing 2004 Requests. It lists specific information and access requests directed to Amex, beginning with documentation used to manage risk reviews of loans at origination, such as Incident Reports, Questionable Activity Reports, fraud flag categories and screening results. Further requests cover IT system alerts, read-only access to the Kabbage platform that KServicing licenses, access to all data fields for each PPP loan, database updates, audit and governance requirements, and APIs for Kore, the PPP Borrower Dashboard and Salesforce. A closing section on general matters for transition asks Amex to confirm, document and transition automated processes that support PPP loan servicing, listing items such as daily loan schedules, forgiveness data ingestion and collections reporting.
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Case 22-10951-CTG Doc 685-3 Filed 03/15/23 Page 1 of 4
Exhibit 3
Case 22-10951-CTG Doc 685-3 Filed 03/15/23 Page 2 of 4
SCHEDULE
KSERVICING 2004 REQUESTS
Specific Information Requests/Access
1. Documentation providing overview and business requirements to manage the risk
reviews of loans at origination: This includes all of the accompanying documentation,
including the following:
● Incident Reports (IRs) and narratives generated in connection with loan reviews
● Questionable Activity Reports (QARs)
● Fraud flag categories with definitions for each flag
● Documentation of business reason business requirements that explain placement of flag
● Documentation of process to clear or confirm each category of suspected fraud
● Results of any screening procedures, including but not limited to Threatmetrix,
Lexis/Nexis, Experian, GIAC and related third-party tools
● Any other KYC/KYB data and documents, including those described in the company’s
AML/BSA program documents
2. IT System Alerts
● Defined and documented system alerts to be sent to KServicing IT/Sr. Management
leads to alert teams of changes to the database environment that require investigation
and validation, to confirm reporting output from Amex-managed systems and delivered
to KServicing bank partners and internal teams to accurately reflect the status of the
portfolio
3. Data Environments & Technical Platforms
● Request for the IT department to provide read-only access to the Kabbage platform that
KServicing licenses to service the loans, allowing the KServicing team to reference the
code within the platform
● Access to databases used to support automated jobs that Amex maintains, that interact
directly with KServicing partner banks. KServicing data operations team requires the
code from Amex system environment to test and validate KServicing partner reporting
deliverables.
4. Access to all data fields associated with each PPP loan, comprising the history from
origination through disbursement, and all other aspects of the loan
● Currently the access that KServicing has is to a shared database environment, with
select fields that the KServicing team has been blocked from accessing and referencing
Case 22-10951-CTG Doc 685-3 Filed 03/15/23 Page 3 of 4
to service PPP loans. For example Kservicing currently does not have access to SSNs,
TINs, beneficial ownership and related SSNs/TINs and ownership percentages.
5. KAmex Database updates
● Designated Amex point of contact who provides support to database updates
○ Example: Amex point of contact to review and understand the need to change an
SBA Loan # to new Loan #, when adding a 2nd loan is required to manage a
reinstatement of the loan
● Ability to document and update the Kore/CoreCredit environment to support the
changing PPP loan servicing workflow
6. Audit/Governance Business Requirements
● Designated Amex point of contact who supports 3rd-party audit & governance
requirements and deliverables
○ Inclusion of Kore and all such related systems within the scope of AmEx’s annual
SOC audits to comply with partner bank contractual obligations made available
to AmEx during due diligence.
7. APIs for Kore, PPP Borrower Dashboard, and Salesforce
● Designated Amex point of contact for KServicing to coordinate/work with for API
management
● Documentation that outlines and explains all APIs ingested/connected to the Kore and
Customer Dashboard environments, and impact the customer’s dashboard and facilitate
the monetary activities on a customer’s account
8. Data Environments & Technical Platforms
● Provide Amex point of contact to KServicing Help Desk to provide provisioning and
troubleshooting support for Kore-related/Core Card system issues
Case 22-10951-CTG Doc 685-3 Filed 03/15/23 Page 4 of 4
General Matters for Transition
9. Tutorial of the full PPP data environment and support of KAmex Technical lead
10. Confirm, document and transition all automated processes managed within the Amex
infrastructure that support KServicing operations, including
● Number of automated processes that support the PPP loan servicing effort
● Name and description of each individual process
● Documentation of process detail for reference
● Code from each process
● Naming convention for file/directories that map to all automated processes
● Access rights/needs for automated reporting, including Amex point of contact to
manage access rights for automated reporting
● 3rd party vendors impacted by and supporting established automated processes that
support PPP loan servicing operations
● Kabbage Amex point of contact for follow up questions/implementation
Documentation of all automated processes include, but are not limited to:
● Daily all loan schedule delivered daily directly to CRB and CB via their SFTP
environments
● Data dictionary for loan schedule raw report
● Data Reporting Script that captures call recording links produced within the Five9
environment, for subpoena document production
● Instructions and deliverables that AMEX data environments are managing for all
SFTP automated file(s) delivered to KServicing vendors and partners
● Forgiveness data ingestion workflow
● Documentation for Direct Forgiveness API deliverables that Amex completed
● Documentation that outlines and explains automated SFTP updates into the
Blackline accounting environment
● Documentation that outlines and explains that management of the dialer file
generated to support collections efforts
● Documentation of workflows established to manage automated reporting for
collections agencies to reference, to deliver charge off accounts for collection
agency to work from
● Processes, and pending changes to processes, that impact and/or change data
reporting outputs automatically saved into the KS data environment
● Documentation of auto-generation of Salesforce tickets that are created by doc
requests made through Kore
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