Bank Watchdogs Propose Third-Party Risk Playbook
Published Date: 9/15/2026
Notice
Summary
The OCC, Board, FDIC, and NCUA (collectively, the agencies) invite comments on this proposed third-party risk management guidance. The proposed guidance would reflect the agencies' supervisory experience and lessons learned through examining banking organizations' third-party risk management practices. In particular, the proposed guidance would discuss the potential benefits that may accrue when a banking organization aligns its third-party risk management practices in relation to the reasonably assessed risk levels specific to each of its third-party relationships. This approach may assist banking organizations in the prioritization of third-party risk management based on material financial risks, compliance with laws and regulations, and resource allocation. The proposed guidance also would help banking organizations consider potential strategies for tailoring their third-party risk management practices according to the banking organization's size, complexity, and risk profile, as well as the nature of its third-party relationships. The agencies plan to rescind and replace existing guidance on third-party risk management to promote consistency and innovation in the banking industry.
Analyzed Economic Effects
4 provisions identified: 4 benefits, 0 costs, 0 mixed.
Encourages Fintech‑Bank Partnerships
The agencies explicitly say the proposed guidance would "encourage responsible innovation" and remove broad or prescriptive language from the 2023 Guidance that "may unduly impede fintechs from entering partnerships with banking organizations."
Rescind and Replace 2023 Guidance
The agencies plan to rescind and replace the Interagency Guidance on Third-Party Relationships: Risk Management (the 2023 Guidance) and related Supplemental TPRM Resources, aiming to "promote consistency and innovation in the banking industry."
Emphasis on Risk‑Based Tailoring
The proposed guidance would emphasize aligning third-party risk management to reasonably assessed risk levels and tailoring oversight according to a banking organization's "size, complexity, and risk profile" and the nature of its third-party relationships.
Guidance Is Non‑Enforceable
The proposed guidance is not an enforceable rule; the agencies say non-compliance with this guidance "will not result in supervisory action." Examiners may still take action for violations of laws, unsafe or unsound practices, or other material risks.
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