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Financial Institution Letter
Extension of Comment Period for Proposed Interagency Guidance on Third-Party Relationships: Risk Management

Summary:

The Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System (Board), and the Office of the Comptroller of the Currency (OCC) (collectively, the agencies) are extending the comment period on the proposed guidance designed to help banking organizations manage risks associated with third-party relationships. In response to commenters’ requests for additional time to analyze and respond to the proposal, the agencies are extending the comment period until October 18, 2021. Originally, comments were due by September 17, 2021.

A copy of the proposed interagency Guidance can be found on the FDIC’s website.

Statement of Applicability: This Financial Institution Letter (FIL) applies to all FDIC-supervised financial institutions.

Highlights:

  • To ensure interested respondents have adequate time to provide thoughtful input regarding the proposed guidance on managing risks associated with third-party relationships, the agencies are extending the comment period until October 18, 2021.
  • The proposed guidance offers a framework based on sound risk management principles for banking organizations to consider in developing risk management practices throughout the life cycle of third-party relationships, including planning to manage the relationship and its risks, due diligence and third-party selection, contract negotiation, oversight and accountability, ongoing monitoring, and termination.
  • The proposed guidance also offers a framework that takes into account the level of risk, complexity, and size of the banking organization and the nature of the third-party relationship, and promotes compliance with applicable laws and regulations, including those related to consumer protection.
  • The proposed guidance also discusses supervisory reviews of third-party relationships.
  • The final guidance would replace the FDIC’s Guidance for Managing Third-Party Risk , and the FDIC would rescind FIL 44-2008 (June 6, 2008).
  • Comments will be accepted until October 18, 2021.

Suggested Distribution:

FDIC-Supervised Institutions

Suggested Routing:

Board of Directors 
Chief Executive Officer 
Chief Financial Officer 
Chief Risk Officer 
Chief Compliance Officer

FIL-62-2021
Attachments
Last Updated: September 7, 2021