Summary of Proposed Third-Party Risk Management Guidance
Updated 10/09/2026
The Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), Federal Reserve Board (FRB), and National Credit Union Administration (NCUA) recently issued Proposed Interagency Guidance with request for comment regarding third-party risk management. This interagency guidance would replace the agencies’ 2023 third-party risk management guidance with the intention of crafting a more principles-based, risk focused model. The proposal emphasizes that banks should tailor their third-party risk management practices according to the specific risks posed by each relationship, as well as the bank’s size, complexity, and risk profile, rather than applying a uniform or checklist-driven approach. The regulators indicated the current guidance may have been interpreted too broadly resulting in excessive compliance burdens, inefficient resource allocation, and potential barriers to innovation and fintech partnerships.
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