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Policy · Proposed guidance

Proposed third-party guidance puts risk differentiation in focus

A September 11 interagency proposal would tailor third-party oversight to the risk of each relationship. The September 15 Federal Register notice sets November 16, 2026 as the comment deadline. The agencies also issued a separate statement about community banks and core service providers.

1 min read · estimatedAI-generated analysis · Methodology

Why it matters

Analysis: reassess whether vendor tiers reflect potential customer harm, financial exposure and substitutability. Less paperwork for a low-impact supplier should free capacity for dependencies that can interrupt servicing, move money or influence credit decisions.

What remains uncertain

The proposed guidance is non-binding supervisory guidance, not a final regulation. Existing legal duties remain separate. The core-provider statement and proposed guidance are distinct documents with different scope.

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