Board of Governors of the Federal Reserve System

I support taking a fresh look at the third-party risk management guidance, particularly as banks are managing larger, more complex vendor relationships and navigating novel, emerging risks.

It is important that the Board continue to foster responsible innovation and facilitate banks' pursuit of third-party arrangements in a manner consistent with safe and sound practices and in compliance with applicable law, including those designed to protect consumers. A principles-based and risk-focused approach may be helpful towards promoting these goals—especially for enabling innovation and competition for vendor services. However, I welcome comments on whether the agencies should provide greater specificity on effective risk management practices relating to cybersecurity or the allocation of responsibilities for consumer protection, record management, and anti-money laundering in bank-fintech partnerships.

In addition, I strongly support the proposed Third-Party Risk Management Guide for Traditional Community Banking Organizations, as a tailored, helpful resource to assist traditional community banks, facing increasingly complex and critical relationships with third-party vendors. I especially welcome feedback from community banks about further enhancements or additional resources that could support their evaluation of complex technology vendors and core service providers.