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WBA Comments on Proposed Interagency Guidance on Third-Party Relationships

By Scott Birrenkott

WBA filed comments this week with FRB, FDIC, and OCC (agencies) on their proposed guidance on managing risks associated with third-party relationships (proposal).

Over the years, the agencies have issued guidance on third-party management for their respective supervised institutions. The agencies have issued the proposal in an effort to promote consistency in their third-party risk management guidance and to clearly articulate risk-based principles on third-party risk management. The proposal is based on the OCC’s existing third-party risk management guidance from 2013.

WBA commented that the proposal presents a welcome opportunity to consolidate and update each agency’s individual existing guidance, and generally supported the effort. In addition to general comments reflecting member experiences in third-party management, WBA did recommend that the agencies consider specific examination procedures in accordance with the guidance, and provide banks with sufficient time to adapt to any final guidance.

Click here to view the letter.