It’s worth noting that the guidance is broadly applicable and applies to all business arrangements. It doesn’t specifically address the various categories or the types of third parties, such as artificial intelligence or fintech firms. But the principles within the guidance will apply to all third parties and third-party relationships. That being said, financial institutions must manage all third-party relationships, but not necessarily to the same extent as the principles within the guidance can be tailored to the relationship. The interagency guidance provides a number of examples, which should not be interpreted as exhaustive, that financial institutions may consider for their due diligence processes. But, the agencies do note that the guidance does not impose any new regulatory requirements. The new interagency guidance may not create any new regulatory requirements for financial institutions, but it is focused on managing various risks associated with outsourcing certain products, services and activities, especially those impacting consumers. The guidance is a reminder to financial institutions that consumer protections The new Interagency Guidance provides consistency and an interagency approach to managing third-party risk. 15 Nebraska Banker
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