Washington DC – October 18, 2021 – In response to the Request for Comment on Proposed Interagency Guidance on Third-Party Relationships the FTA submitted a comment letter to the Office of the Comptroller of the Currency:
The Financial Technology Association (FTA) appreciates the opportunity to respond to this multi-agency request for comment regarding proposed interagency guidance on managing risk associated with third-party relationships (the “RFC”). As outlined in the request, third-party partners, especially those centered on advanced technology, hold substantial promise in increasing banks’ efficiency, reach, and capabilities across a range of important financial services and compliance functions and activities.
The FTA supports the harmonizing of guidance between the regulators as proposed but believes that the guidance would benefit from offering more apparent examples of how banks can weigh the risks and benefits of various relationships and technologies. Specifically, we believe that smaller institutions and community banks may face continued regulatory ambiguity and challenges in properly evaluating partnerships that would help them better serve their customers. Guidance, including through the FAQs, would be beneficial to offer greater specificity in how banks should assess particular partnerships and technologies. This would help modernize offerings and foster the adoption of promising financial technologies that will ensure that the U.S. financial system remains dynamic, innovative, and capable of serving the ongoing needs of consumers and small businesses.