News & Analysis as of

Third-Party Relationships Office of the Comptroller of the Currency

OCC Offers Advice on Fintechs, Marketplace Lenders

In a new bulletin providing supplemental guidance on third-party relationships, the Office of the Comptroller of the Currency (OCC) answered frequently asked questions about the relationships between financial institutions...more

New OCC Bulletin on Third-Party Oversight Highlights Fintech Relationships

by Pepper Hamilton LLP 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

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

by 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

OCC Establishes New Third-Party Risk Management Expectations, Including for Bank Relationships With Marketplace Lenders

by Pepper Hamilton LLP on

The bulletin requires relationships between banks and marketplace lenders to be treated with the same rigor of due diligence and ongoing oversight as other relationships with third parties. On January 24, the Office of...more

The OCC’s Request for Comments and Discussion on the Future of Fintech Regulation

by K&L Gates LLP on

U.S.-based digital banking startups have raised more than $10 billion since 2010, and investment in financial technology (“fintech”) companies has surpassed $24 billion worldwide. These firms are attempting to disrupt the...more

Vendor Management Risks and Controls

by Poyner Spruill LLP on

What are the Risks? In an effort to heighten efficiency and cost effectiveness, many financial institutions choose to outsource certain services to third party vendors. While these providers often play a beneficial...more

Federal Reserve Adds to Agency Guidance on Third Party Relationships

On Dec. 5, 2013, the Federal Reserve joined the list of regulatory agencies that have issued guidance on third party relationships. The Fed guidance supplements the FFIEC Outsourcing Technology Services Booklet (June 2004)...more

OCC Adds Substantial New Risk Management Burdens for Third-Party Relationships

by Ballard Spahr LLP on

The Office of the Comptroller of the Currency (OCC) recently issued a new Bulletin 2013-29 containing substantially more onerous risk management guidance for third-party business relationships (3PRs) of national banks and...more

OCC Issues New Risk Management Guidance For Third Party Relationships

The Office of the Comptroller of the Currency published on October 30, 2013 a new Guidance relating to risk management for third party relationships. This Guidance rescinds OCC Bulletin 2001-47, “Third-Party Relationships:...more

OCC Issues Updated Risk Management Guidance Concerning Third-Party Relationships

by Goodwin on

The OCC issued updated and comprehensive guidance (OCC Bulletin 2013-29, the “Guidance”) to national banks and federal savings associations (collectively, “Banks”) concerning assessment and management of risks associated with...more

OCC Releases Guidance on Third-Party Relationships

by Goodwin on

The OCC issued guidance to national banks and federal savings associations in assessing and managing risks related to third-party relationships. The OCC defines a third-party relationship as “any business arrangement between...more

OCC Releases Guidance on Third-Party Relationships

On October 30, the OCC issued updated risk management guidance for national banks and federal savings associations related to third-party relationships. The banks should...more

Orrick's Financial Industry Week in Review - November 4, 2013

The Fed Approves New Fee Schedules - On October 31, the Fed announced new fee schedules, effective January 2, 2014, for payment services the Federal Reserve Banks provide to depository institutions (priced services). ...more

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