Managing third party vendor relationships has always been an important function in banks. More recently it has become a hot topic for state and federal financial bank regulators. The increasing complexity of what vendors are doing for banks and the related attention to cybersecurity threats all contribute to the greater scrutiny. The 2016 white paper by the OCC, “Supporting Responsible Innovation in the Federal Banking system: An OCC Perspective,” is just one of several guidance five years that focus to a large extent on third parties providing services and technology to banks. Significantly, some examinations have resulted in the regulators imposing settlements and impose civil money penalties on vendors. Previous to the OCC white paper, the CFPB issued third party guidance in 2012, the FFIEC provided guidance on IT service vendors in 2012 and the OCC and the Federal Reserve issued complementary guidance in 2013 on third party relationships and managing outsourcing risks.
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