June 8, 2017 at 2:11 pm

Written by: Lindsay Harden

Yesterday the OCC issued Frequently Asked Questions (“FAQs”) to supplement OCC Bulletin 2013-29, “Third-Party Relationships: Risk Management Guidance.” The FAQs provide helpful guidance to banks on subjects including working with fintech companies, reducing oversight costs for lower-risk third-party relationships, and engaging in marketplace lending arrangements with non-bank entities. Portions of this guidance may be particularly useful for community banks who wish to leverage resources by distributing costs among multiple banks. For example, the OCC clarified in the FAQs that banks using a common third-party service provider may collaborate with each other to meet certain OCC expectations with respect to performing due diligence, contract negotiation, and ongoing monitoring responsibilities. The FAQs also make clear that a bank may outsource certain compliance management functions or collaborate with a group of banks to manage cybersecurity issues, as additional cost saving alternatives.

Entry filed under: cybersecurity, Financial Institutions, FinTech, Regulatory Guidance, Small Business/SBA/Community Banks, Uncategorized.

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