OCC Releases FAQs on Third-Party Relationships
The Office of the Comptroller of the Currency ("OCC") published answers to frequently asked questions ("FAQs") about risk management expectations regarding third-party relationships. The FAQs comprise a supplement to OCC Bulletin 2013-29, which provides risk management guidelines for banks to follow when entering into third-party relationships.
The FAQs provide guidance from the OCC concerning the following issues:
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diligence expectations for third-party relationships that vary relative to risk level;
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the permissibility for banks of collaborating with other banks that use the same third-party risk management providers;
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how to navigate relationships with FinTech companies with respect to risk management; and
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the applicability of OCC Bulletin 2013-29 to third-party mobile payment arrangements.