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Third-Party Risk Management Financial Institutions

Morrison & Foerster LLP

Crypto-Asset Safekeeping: What’s Involved If You’re a Bank (or if You Want to Be One)

On July 14, 2025, the federal banking agencies issued a joint statement to clarify regulatory expectations for banking organizations that provide or are considering providing safekeeping for crypto-assets (“Joint Statement”)....more

Husch Blackwell LLP

New Exemption Order Creates More Flexibility and More Considerations with the Customer Identification Program Rule

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By an exemption order dated June 27, 2025, federal prudential regulators have given banks and credit unions some welcomed flexibility when collecting an individual’s or entity’s taxpayer identification number (TIN) during...more

Integreon

DORA Compliance Part 1: Proactively Meeting DORA Supply Chain Resilience Obligations

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Introduction to DORA and its Implications - As of Jan.17, 2025, the European Union’s Digital Operational Resilience Act (DORA) became enforceable. This new regulatory framework significantly impacts financial institutions and...more

Bracewell LLP

FINRA Facts and Trends: February 2025

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Welcome to the latest issue of Bracewell’s FINRA Facts and Trends, a monthly newsletter devoted to condensing and digesting recent FINRA developments in the areas of enforcement, regulation and dispute resolution. We dedicate...more

Walkers

A comprehensive guide to the BMA's proposed new Operational Resilience and Outsourcing Code

Walkers on

In response to the increasing interconnectedness of financial service providers across global networks, the BMA is proposing to implement a new Operational Resilience and Outsourcing Code for regulated entities across all...more

K&L Gates LLP

Managing Artificial Intelligence: The Monetary Authority of Singapore's Recommendations on AI Model Risk Management

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Introduction and Background - On 5 December 2024, as part of the Monetary Authority of Singapore’s (MAS) incremental efforts to ensure responsible use of artificial intelligence (AI) in Singapore’s financial sector, MAS...more

Barnea Jaffa Lande & Co.

Understanding DORA: An Overview of the Digital Operational Resilience Act

The Digital Operational Resilience Act (DORA) is an EU regulatory framework, aimed at enhancing the financial sector’s ability to withstand and recover from ICT (information and communication technology) disruptions....more

A&O Shearman

Zooming In on AI - #6: AI under financial regulations in the U.S., EU and U.K.

A&O Shearman on

Many governments are grappling with the question of how to regulate artificial intelligence to ensure it is adopted safely and used responsibly without hampering innovation. Governments have generally indicated similar...more

McGlinchey Stafford

Bank Partnerships in an Evolving World

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Financial institutions have utilized service providers for a multitude of purposes over many years. The use of service providers has not historically been a controversial issue, and financial institutions have always had an...more

Venable LLP

Crystal Clear: New Guide on Third-Party Risk Management for Community Banks - and Others

Venable LLP on

It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more

Ballard Spahr LLP

Federal Banking Agencies Issue Guide to Third-Party Risk Management Practices for Community Banks

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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...more

Ballard Spahr LLP

Recent FDIC Consent Orders Reflect Ongoing Scrutiny of Bank Relationships with Fintechs

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In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness concerns relating...more

McGlinchey Stafford

Deep Dive into Payments: Q&A on Bank Partnership Considerations

McGlinchey Stafford on

But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more

Hudson Cook, LLP

Federal Bank Regulatory Agencies Issue Final Joint Guidance for Managing Third-Party Relationship Risks

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On June 6, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued final joint guidance addressing bank management of...more

Davis Wright Tremaine LLP

Federal Banking Regulators Issue Final Third-Party Risk Management Guidance

On June 6, 2023, the Federal Reserve Board of Governors, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency jointly issued final third-party risk management guidance for supervised...more

Latham & Watkins LLP

Agencies Issue Guidance for Banking Organizations on Managing Risk in Third-Party Relationships

Latham & Watkins LLP on

The guidance outlines principles and key considerations for banking organizations as they navigate risks associated with third parties, including fintechs. On June 6, 2023, the Federal Deposit Insurance Corporation...more

Morrison & Foerster LLP

Banking Agencies Issue Joint Third-Party Risk Management Guidance

On June 9, 2023, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) published final joint guidance on managing...more

Sheppard Mullin Richter & Hampton LLP

FFIEC Issues Updated Guidance on Authentication and Access to Financial Institution Services and Systems

On August 11, the Federal Financial Institutions Examinations Council (FFIEC) issued new guidance, providing examples of effective authentication and access risk management principles and practices for financial institutions....more

Perkins Coie

Fintech Legal Report - July 2021

Perkins Coie on

President Biden Issues an Executive Order on Competition with Implications for Financial Institutions - On July 9, 2021, President Biden issued an Executive Order on Promoting Competition in the American Economy. The...more

Nelson Mullins Riley & Scarborough LLP

Bank Regulators Propose Guidance on Risk Management of Third-Party Relationships

The federal bank regulatory agencies issued a request for public comment this week on proposed interagency guidance designed to help banking institutions manage risks associated with third-party relationships....more

Balch & Bingham LLP

Third-Party Risk Management for Financial Institutions: Reassessing Risk in Light of COVID-19

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As part of an effective third-party risk management program, financial institutions should perform ongoing monitoring of the third-party relationship, including review of audited financial statements and risk assessments,...more

Troutman Pepper Locke

OCC Bulletin For Third-Party Oversight Breaks New Ground For Bank Relationships With Fintechs

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New third-party oversight guidance issued by the OCC should spur increased financial innovation at national banks. On March 5, the OCC issued OCC Bulletin 2020-10, Frequently Asked Questions to Supplement OCC Bulletin...more

Seyfarth Shaw LLP

Ninth Circuit Rules That Users, Not Consumers, Must Prove an Authorized Purpose for Obtaining a Consumer Report

Seyfarth Shaw LLP on

Synopsis: Last month, the Ninth Circuit issued an opinion, affirming broad Article III standing and holding that, for permissible-purpose claims, a consumer-plaintiff need allege only that his/her credit report was obtained...more

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