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Banking Agencies Propose More Prescriptive Third-Party Risk Management Framework

calendar_today September 17, 2026 person Alan S. Kaplinsky and Ronald K. Vaske domain ballard-spahr

Proposed guidance would require specific elements in bank policies and programs and could give added significance to FDIC’s proposed industry standard-setting organization Executive Summary The federal banking agencies have proposed new third-party risk management guidance that is more prescriptive than its emphasis on a “risk-based” approach might suggest. In addition to calling for risk-based oversight, the proposal identifies specific elements that banks should address in board-approved policies and throughout the life cycle of third-party relationships, including due diligence, contracting

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