News & Analysis as of

Risk Management Third-Party Relationships

WilmerHale

Interagency Issuances on Bank-Fintech Partnerships Highlights Risks, Opportunities, Importance of Industry Participant Engagement

WilmerHale on

The recent bank regulatory Joint Statement and request for information (RFI) on third-party deposit relationships and bank-fintech partnerships emphasize afresh regulators’ long-standing concern with financial institutions’...more

Morrison & Foerster LLP

Banking Agencies Address Banking Arrangements with Third Parties to Provide Deposit Products and Services

On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

Ballard Spahr LLP on

The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Ballard Spahr LLP

Banking Regulators Seek Comment on Third-Party Relationships with Financial Institutions

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The federal banking regulators are seeking comment to better understand the relationship between financial institutions and third parties that work for them....more

Troutman Pepper

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

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Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

Troutman Pepper

Federal Banking Agencies Issue New Guidebook for Community Banks Managing Third-Party Relationships

Troutman Pepper on

On May 3, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency (collectively, the agencies) released a guidebook aimed at assisting...more

Ballard Spahr LLP

OCC Risk Perspective Report Focuses on Third-Party Relationships with Fintechs

Ballard Spahr LLP on

In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating the overall soundness 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

Goodwin

Agencies Issue Final Guidance on Third-Party Risk Management

Goodwin on

Agencies Issue Final Guidance on Third-Party Risk Management - On June 6, the Federal Reserve, FDIC, and OCC issued final joint guidance (the Guidance) pertaining to banking organizations’ risk management of third-party...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

J.S. Held

European Human Rights Due Diligence (HRDD) Legislation – Preparing for the Future

J.S. Held on

Sustainable social development is increasingly viewed as critical to ensure the future stability of the global economy and planet. This often-overlooked element of the ESG (Environmental, Social, and Governance) agenda is...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

Mitratech Holdings, Inc

Avoiding the “Twilight Zone” of Vendor Cyber Risk

Mitratech Holdings, Inc on

When risk is stranger than fiction - While this might seem a fictitious depiction of how strategy and action gain momentum and approval within an organization, I promise you: It’s not farfetched. Anyone who’s had a few years...more

Ballard Spahr LLP

OCC issues updated FAQs to supplement bulletin on third-party relationships

Ballard Spahr LLP on

On March 5, 2020, the OCC issued a revised set of FAQs designed to supplement OCC Bulletin 2013-29 (Third-Party Relationships: Risk Management Guidance) issued on October 30, 2013.  ...more

Stinson LLP

The Impact of the Coronavirus on the Global Supply Chain

Stinson LLP on

At the end of December, China acknowledged the existence of the coronavirus, and this burgeoning heath crisis is becoming a supply chain problem. China, a major manufacturing hub for materials, products and components being...more

Ballard Spahr LLP

Coronavirus Outbreak Prompts Supply Chain Disruptions

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Now in its third month, the coronavirus outbreak that began in Wuhan, China, has claimed over 2,000 lives and brought one of the world’s most dynamic economies to a near standstill. ...more

Sunstein LLP

May 2019 IP Update: Amazon Enters the Fray of Intellectual Property Disputes

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Amazon.com has become ubiquitous in online retail, dominating the e-commerce marketplace worldwide. For sellers, Amazon acts as a crucial means of reaching customers around the globe. For consumers, it has become an...more

The Volkov Law Group

The Importance of a High-Risk Due Diligence Committee

The Volkov Law Group on

Believe it or not, but companies are still struggling with third-party risk management systems. I know this sounds hyper-critical but many companies continue to hang onto paper due diligence systems (sometimes with or...more

Thomas Fox - Compliance Evangelist

Operationalizing Compliance Through Management of Third-Parties

If you do not manage the third-party relationship it can all go downhill very quickly and you might find yourself with a potential FCPA violation. Now the DOJ has explicitly adopted this approach as a key determination of...more

Thomas Fox - Compliance Evangelist

World Series Banners and Red Flags

The first lesson for the compliance practitioner is that you should actually test your compliance program in high-risk/high-profile situations. The unfurling team likely did practice their unfurling regime but apparently...more

Ballard Spahr LLP

OCC issues risk management principles for new activities

Ballard Spahr LLP on

On October 20, 2017, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2017-43 (the “Bulletin”) outlining principles that OCC-supervised banks should follow to prudently manage the risks associated with...more

Troutman Pepper

New OCC Bulletin on Third-Party Oversight Highlights Fintech Relationships

Troutman Pepper on

On June 7, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2017-21 (Frequently Asked Questions to Supplement Bulletin 2013-29; Third-Party Relationships: Risk Management Guidance). This is the OCC’s...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - Federal Reserve Board Approves Extended Transition Period for Deutsche Bank AG, SVB Financial Group, and UBS Group AG to Conform Investments in Certain "Illiquid Funds" to Requirements of...more

Ballard Spahr LLP

New OCC FAQs on third-party relationships highlight bank arrangements with fintech companies and marketplace lenders

Ballard Spahr LLP 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...more

Thomas Fox - Compliance Evangelist

Deep Dive Due Diligence: Part IV – Level III Due Diligence for 3rd Parties

Today, I continue my exploration of Level III, deep dive due diligence, by discussing how this should be considered for third parties. I am joined this week by Candice Tal, founder and Chief Executive Officer (CEO) of...more

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