Financial Regulators Propose Combined Guidance for Third-Party Risk Management: Expectations for an Expanded TPRM Landscape

Expectations for an Expanded TPRM Landscape

The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) have proposed combined interagency guidance pertaining to third-party risk management (TPRM). The proposed guidance is directed at all banking organizations supervised by these agencies and, if adopted, would replace each agency’s existing guidance on this topic.

Background

On July 19, 2021, a press release announced that the FRB, FDIC, and OCC issued a call for comments on Proposed Interagency Guidance on Third-Party Relationships: Risk Management. While each agency currently has existing guidance on third-party risk management for their respective supervised banking organizations, the proposed guidance aims to create consistency among the agencies and clarify principles on third-party risk management1. The notice states that the proposed guidance is based on the OCC’s existing third-party risk management guidance from 2013. The proposed guidance considers the level of risk, complexity, size of banking organization and the nature of third-party relationships.

The proposed guidance aims to provide risk management principles that banking organizations may use to address risk throughout all stages of third-party relationships.

Third-Party Risk Management Lifecycle

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ABOUT THE AUTHORS

Michael Rosen
Senior Manager, Advisory

Alex Monk
Consultant, Advisory

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