Control of a Set-aside Entity
FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA
Polsinelli Podcast - An International Trade Issue That May Impact Your Business
Protecting IP Through Employment Law
FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II
FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I
On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more
The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more
The federal banking regulators are seeking comment to better understand the relationship between financial institutions and third parties that work for them....more
Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more
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
In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating the overall soundness of...more
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
Agencies Issue Final Guidance on Third-Party Risk Management - On June 6, the Federal Reserve, FDIC, and OCC issued final joint guidance (the Guidance) pertaining to banking organizations’ risk management of third-party...more
Financial technology companies (fintechs) and other third parties in bank partnerships are routinely subject to scrutiny by their banking partner customers. The Federal Reserve System, the Federal Deposit Insurance...more
On July 13, the Federal Reserve, FDIC, and OCC proposed risk management guidance to help banking organizations manage risks related to third-party relationships, including relationships with vendors, FinTech companies,...more
On March 5, 2020, the OCC issued a revised set of FAQs designed to supplement OCC Bulletin 2013-29 (Third-Party Relationships: Risk Management Guidance) issued on October 30, 2013. ...more
On October 20, 2017, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2017-43 (the “Bulletin”) outlining principles that OCC-supervised banks should follow to prudently manage the risks associated with...more
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
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
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
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
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
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
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
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
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