• Outsourcing by Financial Services Companies: Impact of the OCC and FRB Guidelines
  • February 12, 2014 | Authors: Stuart D. Levi; William J. Sweet; James S. Talbot
  • Law Firms: Skadden, Arps, Slate, Meagher & Flom LLP - New York Office ; Skadden, Arps, Slate, Meagher & Flom LLP - Washington Office ; Skadden, Arps, Slate, Meagher & Flom LLP - New York Office
  • Outsourcing has become a critical component of financial institutions’ management of their business operations and control of their costs. In addition, institutions are outsourcing increasingly complex and sensitive banking and financial operations to third parties. In light of these developments, the Office of the Controller of the Currency (OCC) and the Federal Reserve Board (FRB) recently issued guidance on how financial institutions should manage third-party risks. The guidance issued by each agency has particular relevance to outsourcing transactions and provides companies with a roadmap of the key areas of concern to regulators. Institutions also should expect that regulators will ask them to compare their policies and procedures against the new OCC and FRB guidance.