Natlawreview iconNatlawreviewSep 18, 2026 ~1 min source read

Banking Agencies Propose to Replace the 2023 Third-Party Risk Management Guidance and to Rescind the Bank-Fintech Joint Statement

If finalized, the proposal would rescind and replace the June 2023 Interagency Guidance on Third-Party Relationships: Risk Management (the 2023 Guidance), along with rescinding (and at this point not replacing) the "Supplemental TPRM Resources:

Banking Agencies Propose to Replace the 2023 Third-Party Risk Management Guidance and to Rescind the Bank-Fintech Joint Statement

Share this story

Send the public story page.

Useful takeaways from this story.

If finalized, the proposal would rescind and replace the June 2023 Interagency Guidance on Third-Party Relationships:

Risk Management (the 2023 Guidance), along with rescinding (and at this point not replacing) the "Supplemental TPRM Resources:

Comments on the new 2026 Proposed Guidance are due 60 days after publication in the Federal Register (which is a comment deadline of November 10, 2026).

Building the complete brief

The page is ready to read now. The fuller skim-friendly version will appear here automatically.

The useful part

If finalized, the proposal would rescind and replace the June 2023 Interagency Guidance on Third-Party Relationships: Risk Management (the 2023 Guidance), along with rescinding (and at this point not replacing) the "Supplemental TPRM Resources: Comments on the new 2026 Proposed Guidance are due 60 days after publication in the Federal Register (which is a comment deadline of November 10, 2026).

How it works

  • A lighter-touch, expressly non-enforceable framework would recenter third-party risk management on relationship-specific risk assessment, potentially ease the path for bank-fintech partnerships, and retire...

What to take from it

Joint Statement on Banks' Arrangements With Third Parties to Deliver Deposit Products" (Joint Statement) issued June 25, 2024, and the "Third-Party Risk Management: A Guide for Community Banks" that was jointly issued by the FDIC, the Fed and the OCC in May 2024. The agencies' diagnosis is blunt: despite disclaiming any prescriptive intent, the 2023 Guidance was applied as a checklist, drove heightened oversight of relationships without regard to the magnitude or likelihood of the risks they actually posed, and discouraged arrangements with newer and innovative providers.

Keep reading in the app

Open the app view to save this story, compare related coverage, and continue from the same source.

Open in app