News & Analysis as of

Third-Party Risk Management Office of the Comptroller of the Currency

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

McGlinchey Stafford

Bank Partnerships in an Evolving World

McGlinchey Stafford on

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

Ballard Spahr LLP on

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

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

McGlinchey Stafford

Interagency Guidance on Risks Associated with a Third-Party Relationship

McGlinchey Stafford on

On June 6, 2023, the Board of the Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies) issued...more

Hudson Cook, LLP

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

Hudson Cook, LLP on

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

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

Buchalter

FDIC, FRB & OCC Issue Interagency Guidance on Third-Party Relationships: Risk Management

Buchalter on

June 8, 2023 By: Stephanie Shea and Michael Flynn On June 6, 2023, the FDIC, FRB and OCC collectively issued a document entitled, “Interagency Guidance on Third-Party Relationships: Risk Management” (“2023 Guidance”). Prior...more

Mitratech Holdings, Inc

US Regulators Raise Expectations of Third-Party Risk Management

Mitratech Holdings, Inc on

It takes something significant for all the US Banking Regulators – the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) – to come together to pool...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

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

Troutman Pepper Locke

Call to Innovate: Is Your Bank Ready?

Troutman Pepper Locke on

In October 2018 the FDIC became the latest federal financial regulator to announce plans to create an Office of Innovation, following on the heels of the OCC and the CFPB. Originally published in Delaware Banker - Winter...more

Orrick - Finance 20/20

OCC Releases Guidance on Third-Party Relationships

Orrick - Finance 20/20 on

On October 30, the OCC issued updated risk management guidance for national banks and federal savings associations related to third-party relationships. The banks should...more

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