Third Party Relationships: Guidance for Community Banks

Last week, the OCC (Office of the Comptroller of the Currency), the Board of Governors of the Federal Reserve System, and the FDIC (Federal Deposit Insurance Corporation) collectively issued guidance for community banks on Third-Party Risk Management. The guide, coming in at around 30 pages, aims to help community banks develop and implement effective third-party risk management practices and important considerations for each state of the third-party risk management life cycle. We’ve developed a training […]

OCC Assesses a $15 Million Civil Money Penalty for Governance and Oversight of Third-Party Affiliate

Today, the Office of the Comptroller of the Currency (OCC) announced a $15 million civil money penalty against American Express National Bank (American Express). The penalty is a result of American Express failing to govern and oversee a third-party affiliate and for violations of regulations relating to certain efforts to retain small business customers. This is the first CMP issued since the agencies released their interagency guidance on June, 9th. The OCC found that American […]

Interagency Requirements for Third-Party Management Are Finalized

On June 6, 2023, final interagency guidance was issued on managing risks associated with third-party relationships. The guidance provides sound principles that supports a risk-based approach to third-party risk management. It is important that financial institutions include these practices when developing and implementing risk management practices for all stages in the life cycle of third-party relationships. Key Components: Promotes consistency in the agencies’ supervisory approach to third-party risk management. The guidance replaces the Agencies’ existing, […]