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Interagency Third-Party Risk Guidance

United States

United States

2023

Cybersecurity

Overview

The Interagency Guidance on Third-Party Relationships: Risk Management, finalized in June 2023, is a unified supervisory framework issued by the Federal Reserve Board, Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC). It replaces prior agency-specific guidance and outlines risk management expectations for financial institutions when working with third parties.
The guidance establishes a lifecycle approach covering planning, due diligence, contract negotiation, ongoing monitoring, and termination. It applies to national banks, federally insured state banks, U.S. bank holding companies, savings associations, and their third-party service providers, including fintechs, cloud providers, and core banking vendors.

Key Obligations

  • Develop a risk-based third-party risk management framework
  • Conduct comprehensive due diligence on critical third parties
  • Define clear roles, responsibilities, and performance expectations in contracts
  • Monitor third-party activities, cybersecurity, compliance, and financial condition
  • Maintain records of all third-party relationships and risk classifications
  • Ensure board and senior management oversight for critical relationships
  • Report significant third-party disruptions or breaches to regulators

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