Third-Party Arrangements: Joint Statement on Banks' Arrangements With Third Parties to Deliver Bank Deposit Products and Services

Summary

Today the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a joint statement on banks'¹ arrangements with third parties to deliver bank deposit products and services to end users.

Relatedly, the agencies also released a request for information (RFI) on arrangements in which one or more third parties engage with banks to distribute banking products and services to consumers and businesses (referred to as bank-fintech arrangements). More information on the RFI can be found in OCC Bulletin 2024-21.

Highlights

The joint statement

• highlights a number of risks that may be elevated under certain circumstances when delivering deposit products and services through a third party, including operational, compliance, strategic, liquidity, and concentration risks, as well as risks related to consumer protection, end user confusion, and misrepresentation of deposit insurance coverage.
• discusses examples of effective risk management practices that the agencies have observed, which a bank may consider adopting to manage the potential risks from third-party deposit product and service arrangements.
• lists existing agency resources, including guidance, interagency statements, and other issuances for banks to consider.

The OCC's mission is to ensure that national banks and federal savings associations operate in a safe and sound manner, provide fair access to financial services, treat customers fairly, and comply with applicable laws and regulations. Banks are neither prohibited nor discouraged from providing banking products and services to customers of any specific class or type, as permitted by law or regulation.

Further Information

Please contact Miriam Bazan, Financial Technology Policy Specialist, Office of Financial Technology, at (202) 649-5200; or Micah Cogen, Counsel, Chief Counsel's Office, at (202) 649-5490.

Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy

Related Links

• "Joint Statement on Banks' Arrangements With Third Parties to Deliver Bank Deposit Products and Services" (PDF)
• "Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses" (PDF)