News & Analysis as of

Third-Party Risk Risk Management Banks

Alston & Bird

Regulators Focus on Bank-Fintech Arrangements

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Through joint guidance and an information request, federal bank regulators underscored banks’ compliance responsibilities in their banking-as-a-service (BaaS) relationships with third parties. Our Financial Services Team...more

Troutman Pepper

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

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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

Venable LLP

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

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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

Jenner & Block

[Ongoing Program] CLE Relay – Session 3 – Hot Topics in Fintech and Crypto - June 7th, 10:00 am - 11:00 am PDT

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This session will provide a survey of key issues and trends impacting the fintech and digital assets community as well as the future opportunities and challenges presented for these financial products and services. It will...more

Troutman Pepper

FDIC Announces Two More Consent Orders Containing Third-Party Risk Management and Fintech Partnership Orders

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On March 29, the Federal Deposit Insurance Corporation (FDIC) announced two more consent orders containing provisions relating to banks’ third-party risk management programs with respect to banking as a service (BaaS)...more

Nutter McClennen & Fish LLP

Nutter Bank Report: February 2024

The U.S. Department of Justice (DOJ) and state authorities have agreed to a consent order with a large national bank to resolve allegations that the bank engaged in a pattern or practice of lending discrimination by affecting...more

American Conference Institute (ACI)

[Event] 8th Forum on FinTech & Emerging Payment Systems - April 9th - 10th, New York, NY

ACI’s 8th Annual Legal, Regulatory, and Compliance Forum on Fintech & Emerging Payment Systems will provide in-depth guidance on the latest regulatory developments at the Federal and State Level that you need to be aware of....more

American Conference Institute (ACI)

[Event] 29th Annual Flagship Conference on Regulatory Compliance for Financial Institutions - November 21st - 22nd, Toronto, ON,...

Don’t miss the opportunity to gain valuable insights from industry experts at Canadian Institute’s Annual Flagship Conference on Regulatory Compliance for Financial Institutions. This event will equip you with strategies to...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

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

Ballard Spahr LLP

Federal banking agencies issue final interagency guidance on risk management in third-party relationships

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The Federal Reserve, FDIC, and OCC have released final interagency guidance for their respective supervised banking organizations on managing risks associated with third-party relationships, including relationships with...more

Amundsen Davis LLC

Bad Relationships: New Regulatory Guidance for Banks on Managing Risks Associated with Third-Party Relationships

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On June 6, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency jointly released final guidance on managing risks associated...more

Cadwalader, Wickersham & Taft LLP

Banking Agencies Finalize Interagency Guidance on Third-Party Risk Management

On June 6, the three Federal bank regulatory agencies (the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”)), issued final interagency...more

Mayer Brown

Impact of the Banking Crisis on Bank-FinTech Relationships

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The recent banking crisis has highlighted the need for FinTechs to take a strategic approach to their current and future bank partner relationships. With bank regulators focusing their attention on exactly these types of...more

Venable LLP

Bank Provider of BaaS Dinged by OCC; Blueprint for Fintech Partnerships?

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​​​​​​​A recent action by the Office of the Comptroller of the Currency (OCC) highlights how banks need to ensure that they have robust compliance programs for managing risks posed by their banking as a service (BaaS)...more

NAVEX

Staying Ahead of Sanctions – What You Need to Know to Maintain Compliance

NAVEX on

The threats posed by Russia to the Ukraine, and the worldwide implications, are deeply concerning and we denounce the invasion of the Ukraine by Russia and hope that this crisis can be resolved quickly through diplomacy. ...more

Goodwin

CFPB Withdraws Proposal to Delay Debt Collection Final Rules

Goodwin on

In This Issue. The Consumer Financial Protection Bureau (CFPB) withdrew its proposal to delay the Debt Collection Final Rules; the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance...more

Troutman Pepper

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

Manatt, Phelps & Phillips, LLP

FDIC on Marketplace Lending, Supervisory Appeals and Communication

The latest regulator attempting to rein in controls on the marketplace lending industry is the Federal Deposit Insurance Corp. (FDIC). Marketplace lending to consumer borrowers generally runs through state-chartered banks....more

Bradley Arant Boult Cummings LLP

Third Party Service Providers Remain in the Spotlight

Yesterday, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective (the “Semiannual Risk Perspective”). The Semiannual Risk Perspective covers “key issues facing banks, focusing on those...more

Williams Mullen

Managing Risks in Vendor Relationships

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For years, banks have relied on third party vendors to provide specialized products or services, or have used outsourcing as a way to reduce internal operating costs. In the wake of the financial crisis, however, regulators...more

Morrison & Foerster LLP

OCC Issues New Third-Party Risk Management Guidance

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On October 30, 2013, the Office of the Comptroller of the Currency (OCC) issued new guidance on risks presented by third-party relationships, entitled “Third-Party Relationships: Risk Management Guidance” (“2013 Bulletin”)....more

Davis Wright Tremaine LLP

OCC Releases New Third Party Guidance

On October 30, 2013, the OCC published a broad update of its guidance regarding national banks and their third-party relationships. The guidance also applies to federal savings associations (“FSAs”) as well as extending...more

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