“Third-party risk management is a crucial aspect of responsible bank-fintech partnerships. The American Fintech Council supports FDIC, OCC, and the Federal Reserve’s efforts to encourage responsible innovation through the proposed approach to tailoring third-party risk management to the size, complexity, and risk profile of individual banks and their relationships. Community banks should have the flexibility to manage third-party relationships based on the risks those relationships actually present. A more proportionate, risk-based framework would give community banks greater flexibility to invest in technology, pursue responsible partnerships, and deliver the products and services their customers and local businesses need.”

“We are also greatly encouraged by the recognition by the joint agencies on banks’ abilities to leverage standard setting organizations as part of their risk management processes. Leveraging these organizations will result in more efficient and effective examination processes.”

“AFC commends the joint agencies’ efforts to provide greater clarity while maintaining strong standards for safety and soundness. We encourage the agencies to finalize a framework that recognizes the distinct needs of community banks and enables these institutions to focus their resources on supporting the customers they serve.”

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