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CC_He
Visitor 1

Financial Services Addendum

If a company (the Company), that is a customer regulated by a regulator, enters the Financial Services Compliance Program and one of its vendors uses the MS Azure hosting service to host Company's data (under a contract between this vendor and Microsoft), can the Company still exercise audit rights over the Microsoft sub-provider under the Financial Service Addendum or not? So is it possible for the Company to exercise its rights under the Financial Service Addendum even if the Company is not directly the user of the MS Azure hosting service, because this service is conveyed by a supplier?

The chain would be as follows: customer - supplier - subcontractor Microsoft

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JanoschUlmer
Microsoft

@CC_He : In my understanding audit rights would not apply - if the customer is not a direct customer of Microsoft and not running the Azure services themselves, the Financial Services contract amendment from Microsoft does not apply. The customer would have an agreement with the supplier, not Microsoft (at least not for the part of the service hosted by the supplier), the supplier could leverage their own Financial Services contract amendment and membership in the program to fulfill the requirements. 

 

Do you have an account team assigned (Partner Development Manager)? They could be asked to clarify further with internal resources. Also, I would assume that if customer joined the Financial Services Compliance Program there should be a contact option for questions on this program as well. 

Kind regards, Janosch
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v-jillarmour
Community Manager

@CC_He Wow, this is way out of my expertise, but it's possible @JanoschUlmer may have some resources around this, but I'm not positive. Tracking in hopes someone has an answer for us.