On June 6, the FDIC, FRB & OCC issued final interagency guidance intended to assist their respective supervised banking organizations in identifying and managing risks associated with third-party relationships and in complying with applicable laws and regulations. The final guidance replaces and supersedes each agency’s existing third-party guidance “and promotes consistency in the agencies’ supervisory approaches toward third-party risk management,” and incorporates changes based on comments on the proposed guidance from July 2021 (see our previous blog post on the proposed guidance here). The prior sets of guidance from each of the agencies the final guidance rescinds and replaces includes the FDIC’s FIL-44-2008, FRB’s SR Letter 13-19 and CA Letter 13-21, and OCC’s Bulletins 2013-29, 2020-10. The final guidance is effective immediately.
