Skip to content
Action required FDIC / Federal Reserve / OCC Aug 1, 2026

FDIC, Federal Reserve, and OCC interagency guidance on third-party relationships remains baseline framework

The June 6, 2023 Interagency Guidance on Third-Party Relationships: Risk Management remained the controlling federal third-party risk framework during the July 18 to August 1, 2026 period. The guidance rescinded and replaced the FDIC's 2008 third-party risk guidance and sets expectations for planning, due diligence, contract negotiation, ongoing monitoring, and termination.

The June 6, 2023 Interagency Guidance on Third-Party Relationships: Risk Management remained the controlling federal third-party risk framework during the July 18 to August 1, 2026 period. The guidance rescinded and replaced the FDIC's 2008 third-party risk guidance and sets expectations for planning, due diligence, contract negotiation, ongoing monitoring, and termination.

What changed

The interagency framework replaced older FDIC guidance and established a single risk-based baseline for managing third-party relationships.

Compliance perspective

Banks should continue aligning vendor management, fintech partnership oversight, contract review, and monitoring practices to the 2023 interagency framework. Even without a new July 2026 issuance, this guidance remains central to examinations and internal control design.

Key date

Effective date: June 6, 2023.

Need help staying compliant?

Tell us where you operate and what licenses you hold; we'll handle the filings and renewals so changes like this do not catch you off guard.

Keep reading

More regulatory updates

Other recent rule changes our team is tracking.

  • Action CFPB Aug 1, 2026

    RAB Performance Recoveries CFPB settlement cited unlicensed debt collection activity in multiple states

    The CFPB's settlement with RAB Performance Recoveries remains a key federal precedent for treating unlicensed state debt collection activity as a deceptive practice issue. The Bureau said the company pursued collections and judgments in states where it lacked required licenses, and the order barred collection on affected judgments and payment agreements while imposing a civil money penalty.

  • Action California DFPI CA Aug 1, 2026

    California DFPI debt collection licensing regulations remain in force, including annual report and net proceeds requirements

    California's Debt Collection Licensing Act regulations remained in force during the July 18 to August 1, 2026 period, including additional annual report and net proceeds requirements that became effective July 1, 2025. The framework continues to govern application, operational, and reporting requirements for debt collectors in California.

  • Action OCC Aug 1, 2026

    OCC Interpretive Letter 1192 on state money transmitter licensing preemption for national banks

    OCC Interpretive Letter 1192, dated May 12, 2026, states that national banks are not required to comply with state money transmitter licensing requirements where those requirements would condition the exercise of federally authorized banking powers. The letter remained an important federal-state boundary issue during the July 18 to August 1, 2026 period.