risk management

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On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the “Third-Party Risk Management: A Guide for Community Banks” (the “Guide”), presenting it as a resource for community banks to bolster their third-party risk management programs, policies, and practices.… Continue Reading

On December 16, 2021, the Office of the Comptroller of the Currency (“OCC”) released draft principles for climate-related financial risk management for large banks.  Feedback must be submitted by February 14, 2022.

The OCC is looking for feedback on all aspects of the draft principles.  Noting the emerging risks to banks and the financial system due to impending climate change, the OCC recognized both physical risks and transition risks to banks, particularly large banks (with over $100 billion in total consolidated assets).… Continue Reading

Last week, the OCC, Federal Reserve Board, and FDIC issued proposed guidance for banking organizations on managing risks associated with third-party relationships, including those with financial technology-focused entities such as bank/fintech sponsorship arrangements.  The agencies have made clear that if banks have ineffective risk management processes, agency examiners will closely scrutinize their third-party risk management and identify and report deficiencies in examination reports and recommend appropriate supervisory actions.… Continue Reading

The Federal Reserve, FDIC, and OCC have released proposed interagency guidance for banking organizations on managing risks associated with third-party relationships, including relationships with financial technology-focused entities such as bank/fintech sponsorship arrangements.  The proposal is the first time that the three agencies have proposed third-party risk management guidance on an interagency basis. … Continue Reading

Ballard Spahr is proud to partner with Venminder, Inc., on this podcast posted today discussing third-party vendor risk management concerns of financial institutions and service providers. Hosted by Venminder’s Chief Risk Officer Branan Cooper, the podcast features Glen Trudel, a partner in Ballard Spahr’s Consumer Financial Services Group with extensive experience in this area.… Continue Reading

On October 20, 2017, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2017-43 (the “Bulletin”) outlining principles that OCC-supervised banks should follow to prudently manage the risks associated with offering new, modified, or expanded products and services.

Acting Comptroller Keith Noreika, in recent remarks, confirmed the OCC’s efforts to explore and support responsible innovation, and the Bulletin indicates that it “is consistent” with that support. … Continue Reading