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Office of Comptroller of Currency Issues FAQs on Managing Third-Party Relationships

On June 7, the Office of the Comptroller of the Currency (OCC) issued frequently asked questions (FAQs) to supplement OCC Bulletin 2013-29, “Third-Party Relationships: Risk Management Guidance,” which was originally issued on October 30, 2013. These FAQs address questions from national banks and federal savings associations. The FAQs and underlying OCC Bulletin 2013-29 apply to all national banks and federal savings associations, and primarily focus on defining third-party relationships, tips for reducing oversight costs, and guidance on engaging with FinTech companies.

The OCC intends to review banks’ questions on OCC Bulletin 2013-29 from time to time and issue future FAQs or other guidance when it deems necessary.

The full text of the OCC FAQs is available here.

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About this Author

Christina J. Grigorian, Banking legal Specialist, Katten Muchin Law firm
Special Counsel

Christina J. Grigorian counsels clients in all matters related to banks, bank holding companies, and state and foreign-licensed consumer and commercial lenders. Ms. Grigorian provides advice to the firm’s financial institution clients concerning structural and operational issues, including legislative developments impacting such operations, and has worked with companies and individuals in the establishment of de novo entities, including national banks, federal savings banks and state-chartered institutions, as well as state-licensed lenders. She has also counseled clients with respect to...

Lauren Haahr, Katten Law Firm, Financial Services Attorney

Lauren Haahr is an associate in the Financial Services practice. She is admitted only in Maryland, and is supervised by principals of the Firm who are admitted to the District of Columbia Bar.