The Office of the Comptroller of the Currency (OCC), Federal Reserve Board, Federal Deposit Insurance Corporation (FDIC) and National Credit Union Administration (NCUA) have extended the comment period for proposed guidance on third-party risk management. The deadline has been moved from November 16 to December 16, 2026, giving banks and other affected institutions an additional month to review the proposed framework and submit comments. The proposal focuses on how financial institutions should identify, assess and manage risks arising from relationships with external vendors and service providers.
The extension is particularly relevant as financial institutions increasingly depend on technology vendors, fintech partners, cloud providers and other external service providers for critical activities. Third-party relationships can create interconnected operational, cybersecurity, compliance and resilience risks, making vendor due diligence and ongoing oversight increasingly important. The OCC’s proposed guidance remains open for comment, so the December 16 deadline is not a final regulatory requirement. Banks and other institutions should therefore distinguish between proposed supervisory expectations and requirements that have already taken effect.
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