Re: Comment on Proposed Interagency Guidance on Third-Party Relationships: Risk Management (Docket No. OP-1752; FDIC RIN 3064-ZA26; Docket ID OCC-2021-0011)
VIA ELECTRONIC SUBMISSION
Ann E. Misback
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue NW
Washington, DC 20551
James P. Sheesley, Assistant Executive Secretary
Attention: Comments-RIN 3064-ZA26, Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington D.C. 20429
Chief Counsel’s Office
Attention: Comment Processing
Office of the Comptroller of the Currency
400 7th Street SW, Suite 3E-218
Washington, DC 20219
Ladies and Gentlemen:
The American Bankers Association is pleased to comment on the interagency third-party risk management guidance proposed by the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC)(collectively, the agencies). The proposed guidance describes the third-party risk management life cycle and identifies principles applicable to the six stages of a third-party relationship, including: (1) strategy and planning; (2) due diligence; (3) contract negotiation; (4) governance and oversight; (5) monitoring; and (6) termination.
Over the years, each of the agencies has issued third-party risk management guidance for its respective supervised institutions. To promote consistency across the agencies, regulators are jointly seeking comments on the proposed guidance, which is based largely on OCC Bulletin 2013-29. The proposed joint guidance would replace each agency’s existing third-party risk management guidance.
ABA supports this joint effort. This undertaking is especially valuable as a bank’s ability to compete in the marketplace depends increasingly on the institution’s ability to leverage the expertise of third-party service providers and manage those relationships prudently.
Below are the highlights of our comments on the proposal.
Download the comment letter to read the full text.