Summary:
The Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency (the Agencies) issued a joint statement to outline potential risks related to arrangements between banks and third parties to deliver bank products and services and examples of risk management practices to manage potential such risks. The joint statement does not establish new expectations.
The agencies also published a request for information (RFI) in the Federal Register that seeks information and comment on bank-financial technology (or “fintech”) arrangements, including associated risk management practices and implications.
Statement of Applicability: The contents of, and material referenced in, this FIL apply to all FDIC-supervised financial institutions.
Highlights:
- The joint statement discusses potential risks related to arrangements between banks and third parties to deliver bank deposit products and services to end users. The statement also highlights examples of risk management practices implemented by banks to manage such risks.
- The joint statement does not alter existing legal or regulatory requirements or establish new supervisory expectations.
- Banking organizations are neither prohibited nor discouraged from providing banking services to customers of any specific class or type, as permitted by law or regulation.
- A bank’s use of third parties to perform certain activities does not diminish its responsibility to comply with all applicable laws and regulations.
- The statement does not address relationships that are only between banks and their direct customers of traditional bank deposit products and services not involving third parties.
- The RFI is intended to gather additional information on deposit arrangements addressed in the joint statement, as well as other types of arrangements in the areas of payments and lending. The RFI will be published in the Federal Register. The RFI seeks information and comment on the nature of certain bank-fintech company arrangements, as well as effective risk management practices and the implications of such arrangements.
- The FDIC encourages comments in response to the RFI from all interested parties; comment period is 60 days, but may be extended.