Federal ReserveVendor / TPRMSeptember 15, 2026

OCC, Fed, FDIC & NCUA Propose Unified Third-Party Risk Management Guidance

Four federal banking regulators are jointly proposing updated third-party risk management guidance that emphasizes risk-proportionate oversight and replaces existing agency-specific guidance. The proposal encourages institutions to tailor their vendor management programs to the actual risk level of each relationship, size, and complexity of the organization. This is directly relevant to any bank or fintech that relies on third-party technology providers, crypto rails, or payment processors.

What to do

Map your current third-party inventory against the proposed risk-tiering framework and identify any vendor relationships that may require enhanced due diligence under the new guidance before it is finalized.

Who this affects

Bank / Credit UnionTrust CompanyFintech / NeobankPayments CompanyMoney Services Business

Does this affect your program?

Pick your institution type for an instant read on whether you're in scope — then see exactly which sections of your own policies this changes.

Source

Read the official publication

This radar entry is educational and does not constitute legal advice. Summaries are AI-assisted and grounded in the linked official source; always verify against the primary source and consult qualified legal counsel for jurisdiction-specific guidance.

Related developments

OCC

OCC Updates Cybersecurity Examination Work Program for Banks

The OCC has revised its Cybersecurity Supervision Work Program (CSW), which examiners use to assess cybersecurity risk at national banks and federal savings associations, updating its structure and references to reflect the evolving threat landscape and adoption of standardized frameworks. For compliance and risk officers at banks, neobanks, and trust companies under OCC supervision, this signals updated examiner expectations around cybersecurity controls and preparedness. Crypto custodians and fintechs with bank charters or partnerships should also take note, as vendor and third-party cybersecurity risk is often assessed through this lens.

FDIC

FDIC Joins Interagency Third-Party Risk Management Guidance Proposal

The FDIC is participating in the same four-agency interagency proposal to update third-party risk management guidance for banking organizations, signaling broad regulatory alignment on vendor oversight expectations. FDIC-supervised institutions, including state non-member banks that frequently partner with fintechs and crypto firms, should treat this proposal as a preview of future examination standards. The agencies intend to rescind and replace existing guidance, making this a significant structural change for compliance programs.

OCC

OCC Joins Interagency Proposed Third-Party Risk Management Guidance

The OCC is co-issuing the same interagency third-party risk management proposal alongside the Fed, FDIC, and NCUA, signaling a unified supervisory approach across the federal banking agencies. National banks and federal savings associations should treat this as a near-certain indicator of forthcoming binding expectations on vendor oversight. The proposal's emphasis on risk-proportionate controls is particularly relevant for institutions using crypto or fintech service providers.

Federal Reserve

Fed Proposes Third-Party Risk Management Guide for Community Banks

The Federal Reserve is seeking comment on a proposed guide specifically for community banking organizations on managing third-party relationship risks. The guide draws on supervisory experience and addresses key risk categories most common to smaller institutions. Compliance officers at community banks or fintechs partnering with them should note this could reshape due diligence and oversight expectations for vendor relationships.

Stay ahead of every rule change

PliOS monitors FinCEN, OCC, OFAC, the SEC and CFTC and tells you which of your policies each new rule affects — with the edit already drafted. Start free.

Run My Free Assessment