White Paper

OCC 2013-29: Taking a Comprehensive Approach to Third-Party Risk Management

Banks and savings associations are no strangers to strict governing rules and guidelines which range from the Gramm-Leach-Bliley Act (GLBA) to Bank Secrecy Act/Anti-Money Laundering (BSA/AML) laws. In most cases, new bulletins created by governing bodies such as the Office of the Comptroller of the Currency (OCC) serve primarily to add clarification to previously established laws.

This was not the case with OCC Bulletin 2013-29, however, which was released in October 2013. This bulletin is described as “the new rule of law,” because while it does make references to previous laws, at the same time it introduces a brand new set of guidelines and regulations. In fact, one of the biggest changes OCC 2013-29 established was that compliance was no longer an issue assigned to the board of directors — senior management now shares this responsibility. This change alone was enough to cause real concern among many bank managers followed by the question, “How do I satisfy this new regulatory responsibility?”

In this white paper, we’ll take a closer look at the key provisions of the OCC 2013-29 (referred hereafter as the bulletin or the new rule of law). We’ll also address the key takeaways of the bulletin as well as strategies bank executives can follow to meet the requirements of the bulletin.

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