The Federal Financial Institution Examination Council (FFIEC) issued Third Party Relationships: Interagency Guidance on Risk Management to describe sound risk management principles to consider for financial institutions with any type of third-party relationships. In June 2023, the FDIC, The Federal Reserve, and the OCC issued joint guidance on managing risks with third party relationships. It is critical for financial institutions to know who they are partnering and conduct proper due diligence.

• Potential impact of CFPB’s plan to directly supervise certain general-use digital consumer payment applications on third party oversight
• Lessons/best practices regarding third party oversight coming out of the near failure of Silicon Valley Bank
• CFPB’s focus on the fact that funds in popular payment apps may lack
• Need to carefully consider partnership structures and oversight