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
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Federal banking agencies issue guide for community banks on conducting due diligence on fintech companies
By Glen P. Trudel & Ronald K. Vaske on
The OCC, FDIC, and Federal Reserve Board have issued a guide that is intended to assist community banks in conducting due diligence when considering relationships with financial technology (fintech) companies (Guide).
The issuance of the Guide follows the agencies’ July 2021 release of 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. … Continue Reading
Federal banking agencies issue proposed interagency guidance on risk management in third-party relationships; Ballard Spahr to hold Aug. 6 webinar
By Ronald K. Vaske on
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
OCC report identifies use of third-party service providers and consumer compliance as key risks for federal banking system
By Scott A. Coleman on
Posted in OCC, Regulatory and Enforcement
Last week, the OCC released its Semiannual Risk Assessment for Fall 2017 highlighting credit, operational, and compliance risks to the federal banking system. In addition to easing in commercial credit underwriting processes, the increasing complexity of cybersecurity threats, and ongoing challenges in complying with Bank Secrecy Act (BSA) requirements, the other key risks identified by the OCC were increasing concentration in third-party service providers for critical operations and challenges in consumer compliance risk management for banks due to the increasing complexity in consumer compliance regulations. … Continue Reading
New OCC FAQs on third-party relationships highlight bank arrangements with fintech companies and marketplace lenders
By Scott M. Pearson on
The Office of the Comptroller of the Currency has issued a new bulletin (2017-21) containing fourteen frequently asked questions to supplement OCC Bulletin 2013-29 entitled “Third-Party Relationships: Risk Management Guidance.” The 2013 bulletin provided updated guidance for managing operational, compliance, reputation, strategic, and credit risk presented by third-party business relationships of national banks and federal savings associations.… Continue Reading