Bring It On Home
As FedFin’s recent in-depth report makes clear (see FSM Report VENDOR9), the inter-agency proposal on third-party risk management is anything but the technical clean-up for which many have mistaken it. By extending the full scope of bank safety-and-soundness and consumer-protection rules to anyone with whom a bank does business of any sort, the proposal is nothing short of a sweeping effort to export banking rules across the financial sector. We doubt it will come up at Tuesday’s Senate Banking hearing with all of the banking agencies but the FRB – Randy Quarles already got a hearing all his own, (see Client Report REFORM206). But, just because the outsourcing proposal per se won’t be raised in the questioning doesn’t mean it won’t feature in many of the answers.

AL080221.pdf