On July 13, 2021, the Federal Reserve Board (FRB), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released a joint request for comment to their Proposed Interagency Guidance on Third-Party Relationships: Risk Management. The agencies have issued this proposed guidance in response to industry feedback requesting alignment among the agencies’ third-party risk management (TPRM) guidance. The deadline for comments to be submitted is September 17, 2021.
Protiviti issued a Flash Report explaining the purpose of the guidance and providing recommendations for actions banks can take now. Mainly, we recommend that organizations, especially those that are not regulated by the OCC, review the proposed guidance and begin to address gaps in their TPRM programs. Specifics areas to address are mentioned in the Flash Report, available here.