Alert

June 7, 2017

OCC Releases FAQs Regarding Third-Party Relationships Guidance

On June 7, 2017, the Office of the Comptroller of the Currency issued frequently asked questions to supplement OCC Bulletin 2013-29, "Third-Party Relationships: Risk Management Guidance," which was originally issued October 30, 2013.

OCC Bulletin 2013-29 provides guidance to national banks and federal savings associations for assessing and managing risks associated with third-party relationships. The FAQs provide further explanation of the guidance outlined in OCC Bulletin 2013-29, including information regarding fintech and marketplace lending. In regards to fintech and marketplace lending specifically, the FAQs address the following questions:

• What is a third-party relationship?
• Is a fintech company arrangement considered a critical activity?
• Can a bank engage with a start-up fintech company with limited financial information?
• How can a bank offer products or services to underbanked or underserved segments of the population through a third-party relationship with a fintech company?
• What should a bank consider when entering a marketplace lending arrangement with nonbank entities?
• Does OCC Bulletin 2013-29 apply when a bank engages a third party to provide bank customers the ability to make mobile payments using their bank accounts, including debit and credit cards?