Jim and Mark submit comments on the proposed Fed, OCC, FDIC guidance dealing with third party risk management for banks.
CRINDATA™ Chairman and Chief Strategy Officer Jim Freis and CEO Mark Stetler submitted comments on Proposed Interagency Guidance on Third Party Relationships: https://www.federalregister.gov/documents/2021/07/19/2021-15308/proposed-interagency-guidance-on-third-party-relationships-risk-management. The comments appear here: https://www.regulations.gov/document/OCC-2021-0011-0001/comment.
The most comprehensive current regulatory requirements for third party risk management are the OCC’s Third Party Relationships: Risk Management: https://www.occ.gov/news-issuances/bulletins/2013/bulletin-2013-29.html, supplemented by OCC’s Third-Party Relationships: Frequently Asked Questions to Supplement OCC Bulletin 2013-29: https://www.occ.gov/news-issuances/bulletins/2020/bulletin-2020-10.html.
The proposed guidance updates regulators’ advice and expectations when banks contract with third party service providers to provide products and services to banks and indirectly to banks’ customers. CRINDATA believes the proposed guidance adds important clarity to the regulators’ expectations about third party service provider risk management but also believes that the final guidance should incorporate and be consistent with the regulators’ other important regulatory stance on third party risk management, the Computer-Security Incident Notification: Notice of Proposed Rulemaking: https://www.occ.gov/news-issuances/bulletins/2021/bulletin-2021-3.html.
“Banks and regulators have recognized the critical roll outsourcing plays in the modern banking system and regulators are developing new regulations and revised guidance that matches the importance played by non-banks in the system, ” said Freis, Chairman and Chief Strategy Officer of CRINDATA. “Regulators are memorializing expectations that banks understand and actively manage not only the risks of their third party service providers but also the risks that arise from parties (i.e., subcontractors) on which the third party service providers rely,” said Freis.
About Jim Freis:
Jim has devoted his career to promoting the integrity of the global financial markets. He is best known in the United States as the longest-serving Director (2007 to 2012) of the United States Treasury Department’s Financial Crimes Enforcement Network (FinCEN), overseeing regulations covering the broadest range of financial institutions in coordination with their primary licensing authorities, and for applying data-driven efforts to combat fraud exposed through the Global Financial Crisis. After FinCEN, Jim was based in Frankfurt, Germany with the Deutsche Börse Group, Europe’s largest provider of systemically significant financial market infrastructures, responsible for overseeing compliance and relations with global regulators including in the implementation of a holistic internal control system approach among Risk, Compliance, Information Security and Outsourcing oversight functions.
About CRINDATA:
CRINDATA, LLC (www.CRINDATA.com) offers unique cloud-based solutions to financial institutions who must actively manage their critical third-party relationships (including their indirect relationships with subcontractors) and must prepare for and mitigate business disruptions management and cybersecurity events originating anywhere in the chain of service providers and subcontractors. Concurrently, CRINDATA helps third party service providers like core systems, payments providers, transaction motoring solutions, banker’s banks, and corporate credit unions, by substantially simplifying the due diligence interactions with financial service companies and by providing a complaint, common platform to manage business disruptions and cybersecurity events when they occur.
Reach CRINDATA at info@crindata.com
202.990.6990
