New Interagency Guidance on Third-Party Risk Management, Compliance and Recent Consent Orders


Third party relationships, whether for core data processing, loan referrals, website hosting or any of the other vast array of services, are expected to be managed in a manner that ensures continued regulatory compliance and sound risk management. In recent years it has also become more common for financial institutions to partner with fintech companies to offer products or services under unique and innovative structures. On June 6, 2023 the FRB, FDIC and OCC issued final joint guidance intended to assist banking organizations manage third party relationship risks. The Interagency Guidance on Third-Party Risk Relationships: Risk Management rescinds and replaces certain prior guidance on the topic. We will provide an overview of the Guidance, identify what has been rescinded and include key take-aways and practice pointers. Our presenters will also share insight into current challenges involving “vendor” third-party risk management.

This session will also cover the uptick in recent consent orders that focus on consumer harm resulting from poor risk management practices.  Areas impacted have included loan and mortgage servicing, as well as deposit operations.

Anne M. McEvilly
President & CEO
Aldrich & Bonnefin, PLC

Sean Kiester
Senior Director, Vendor Management
Fremont Bank