The banking agencies have proposed sweeping standards that would hold all of the banking organizations they govern responsible for the safety and soundness, consumer compliance, and perhaps even diversity of a wide range of third-party business arrangements that now expressly bring in affiliates, subsidiaries, and parent holding companies along with the full scope of outsourced product and service relationships, marketing partnerships, joint offerings, and even use of a third-party mobile phone platform. Much of what would be required of banks may be feasible within contractual relationships, but the guidance would apply even when there is no exchange between the bank and a third party.

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