News & Analysis as of

Office of the Comptroller of the Currency Third-Party

McGlinchey Stafford

Bank Partnerships in an Evolving World

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Financial institutions have utilized service providers for a multitude of purposes over many years. The use of service providers has not historically been a controversial issue, and financial institutions have always had an...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

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

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As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

McGlinchey Stafford

Deep Dive into Payments: Q&A on Bank Partnership Considerations

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But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more

Amundsen Davis LLC

Insights from the OCC Semiannual Risk Perspective

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On June 14, 2023, the Office of the Comptroller of the Currency (OCC) published its Semiannual Risk Perspective which identifies key issues facing the federal banking system. This highly anticipated report comes in the wake...more

McGlinchey Stafford

Interagency Guidance on Risks Associated with a Third-Party Relationship

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On June 6, 2023, the Board of the Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies) issued...more

Hudson Cook, LLP

Federal Bank Regulatory Agencies Issue Final Joint Guidance for Managing Third-Party Relationship Risks

Hudson Cook, LLP on

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

Latham & Watkins LLP

Agencies Issue Guidance for Banking Organizations on Managing Risk in Third-Party Relationships

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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

Wilson Sonsini Goodrich & Rosati

Guardrails for Bank-Fintech Partnerships: The Federal Banking Agencies Finalize Third-Party Risk Management Expectations

The Board of Governors of the Federal Reserve System (Fed), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) issued the long-awaited...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

Jenner & Block

Client Alert: Bank-Fintech Partnerships Update: Banking Agencies Finalize Key Risk Management Guidance

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On June 6, 2023, federal banking agencies issued final Interagency Guidelines on Third-Party Relationships detailing their expectations for banks in establishing risk management practices with third-parties—including...more

Katten Muchin Rosenman LLP

Bank/Fin-Tech Agreements: Re-Assessment Required Given New Regulatory Guidance on Third-Party Servicing Agreements

On June 6, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Federal Reserve), and the Federal Deposit Insurance Corporation (FDIC) (collectively, the Banking Agencies)...more

Buchalter

FDIC, FRB & OCC Issue Interagency Guidance on Third-Party Relationships: Risk Management

Buchalter on

June 8, 2023 By: Stephanie Shea and Michael Flynn On June 6, 2023, the FDIC, FRB and OCC collectively issued a document entitled, “Interagency Guidance on Third-Party Relationships: Risk Management” (“2023 Guidance”). Prior...more

Ballard Spahr LLP

Federal Agencies Propose Reconsideration of Value Guidance

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A group of federal agencies have proposed reconsideration of value (ROV) guidance for residential real estate valuations. The agencies are the Comptroller of the Currency (OCC), Consumer Financial Protection Bureau (CFPB),...more

Mitratech Holdings, Inc

US Regulators Raise Expectations of Third-Party Risk Management

Mitratech Holdings, Inc on

It takes something significant for all the US Banking Regulators – the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) – to come together to pool...more

Morgan Lewis - All Things FinReg

The Antitrust Risk of the Federal Banking Agencies’ Proposed Risk Management Guidance

As highlighted previously, three federal banking agencies (the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency) recently issued proposed risk management...more

Sheppard Mullin Richter & Hampton LLP

FFIEC Issues Updated Guidance on Authentication and Access to Financial Institution Services and Systems

On August 11, the Federal Financial Institutions Examinations Council (FFIEC) issued new guidance, providing examples of effective authentication and access risk management principles and practices for financial institutions....more

Perkins Coie

Fintech Legal Report - July 2021

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President Biden Issues an Executive Order on Competition with Implications for Financial Institutions - On July 9, 2021, President Biden issued an Executive Order on Promoting Competition in the American Economy. The...more

Pillsbury Winthrop Shaw Pittman LLP

Congress Moves to Repeal OCC’s “True Lender” Rule

The Senate has voted to repeal the True Lender Rule using the Congressional Review Act, a measure allowing Congress to disapprove of agency actions and nullify recently adopted administrative rules. The True Lender Rule...more

Nelson Mullins Riley & Scarborough LLP

OCC Finalizes its “True Lender” Test: Paving the Way for Bank & Non-Bank Partnerships

The Office of the Comptroller of the Currency (“OCC”) issued its long-anticipated final rule on Oct. 27, to establish a “simple, bright-line test” to determine when a national bank or federal savings association has made a...more

King & Spalding

OCC Requests Advice on the Nature of the Digital

King & Spalding on

The Office of the Comptroller of the Currency (OCC) released an Advance Notice of Proposed Rulemaking (ANPR) on June 4, 2020, announcing a review of 12 CFR part 7, subpart E related to national bank electronic activities and...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

Troutman Pepper

Call to Innovate: Is Your Bank Ready?

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In October 2018 the FDIC became the latest federal financial regulator to announce plans to create an Office of Innovation, following on the heels of the OCC and the CFPB. Originally published in Delaware Banker - Winter...more

Ballard Spahr LLP

OCC Identifies Safety and Soundness Risks to National Banks and Federal Savings Associations and Supervisory Priorities

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A new report issued by the federal Office of the Comptroller of the Currency (OCC) identifies top safety and soundness risks to national banks and federal savings associations, as well as OCC supervisory priorities for the...more

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