Is it allowed for community banks in the USA to outsource critical functions to third-party vendors without a formal risk management framework?

Last updated on October 3, 2025

No, it is not allowed. As of May 2024, the Federal Reserve, FDIC, and OCC jointly issued a Third-Party Risk Management Guide specifically for community banks. This guide mandates that banks must establish a formal risk management framework when outsourcing critical functions to third-party vendors. The framework should include due diligence, contract structuring, ongoing monitoring, and contingency planning. The guidance emphasizes that failure to manage third-party risks can lead to operational, compliance, and reputational harm. It also outlines governance practices and life-cycle management for third-party relationships. This regulation aims to ensure that community banks maintain safety and soundness while leveraging external services.

 

https://www.federalreserve.gov/publications/2024-may-supervision-and-regulation-report-regulatory-developments.htm

5/3/2024

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