ICBA told regulators it supports their efforts to consolidate guidance on third-party risk management while providing recommendations on the proposed interagency guidance.
Background: The agencies are proposing interagency guidance based on OCC guidance issued in 2013, which ICBA said is a step toward further policies that fully recognize the potential benefits of community bank-fintech partnerships.
Comments: ICBA said the agencies should:
- Consider how improvements to the process of developing and implementing the guidance—such as employing comment opportunities—will enhance the utility of this and other guidance.
- Continue exploring additional policies that would spur more agile supervisory responses, such as growing the use of agency “sprints,” incorporating pilot programs and sandboxes, and facilitating shared due diligence.
- Structure the guidance so it can be further tailored.
ThinkTECH: The 2022 ICBA ThinkTECH Accelerator program will feature virtual and in-person visits to support community bank-fintech collaborations.
