News & Analysis as of

Federal Reserve Third-Party Service Provider Office of the Comptroller of the Currency

King & Spalding

Fed Follows Earlier OCC, FDIC, and NCUA Orders Allowing Banks to Collect TIN Information from Third Parties

King & Spalding on

On July 31, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an exemptive order in coordination with the Board of Governors of the Federal Reserve System (the “Fed”) that allows...more

Cozen O'Connor

Final Interagency Guidance on Managing Risks Associated with Third-Party Relationships

Cozen O'Connor on

On June 6, 2023, the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency and Federal Deposit Insurance Corp. (collectively, the “Agencies”) issued final interagency guidance that...more

Venable LLP

Banking Agency Guidance on Third Party Relationships

Venable LLP on

Financial technology companies (fintechs) and other third parties in bank partnerships are routinely subject to scrutiny by their banking partner customers. The Federal Reserve System, the Federal Deposit Insurance...more

Sheppard Mullin Richter & Hampton LLP

Federal Agencies Request Comments on Risk Management Guidance for Third-Party Relationships

On July 13, the Federal Reserve, FDIC, and OCC proposed risk management guidance to help banking organizations manage risks related to third-party relationships, including relationships with vendors, FinTech companies,...more

Nutter McClennen & Fish LLP

Nutter Bank Report, June 2017

Supreme Court: Bank That Buys Debt for Its Own Account Is Not Debt Collector - The U.S. Supreme Court recently held that a bank that collects on debts it has bought and holds “for its own account” is not a debt collector...more

Carlton Fields

Banks to Broaden Reporting of Suspicious Cyber Activity; Regulators Propose “Enhanced” Cybersecurity Standards

Carlton Fields on

The fourth quarter of 2016 has seen an uptick in regulatory activity respecting the financial services sector in the cybersecurity space, both at the state level as previously discussed (here) and on the federal level....more

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