www.marktreichel.com

https://www.linkedin.com/in/mark-treichel/

Key Points:

1. Federal banking agencies released a statement on potential risks of banks using third parties to deliver deposit products and services.

2. Highlights risk management practices for banks to consider when managing these arrangements.

3. Reemphasizes existing guidance; does not create new requirements or expectations.

4. Identifies potential risks in areas like:
   - Operational and compliance issues
   - Growth and liquidity management  
   - Misrepresentation of deposit insurance

5. Provides examples of effective risk management practices, including:
   - Robust governance and third-party risk management
   - Managing operational and compliance implications
   - AML/CFT and sanctions compliance 
   - Managing growth, liquidity and capital impacts
   - Addressing deposit insurance misrepresentations

6. Includes list of existing regulatory resources and guidance for banks to reference

Key Takeaways:
- Increasing use of third parties for deposit products raises potential risks
- Banks remain responsible for regulatory compliance even when using third parties
- Effective risk management and oversight is crucial as these arrangements evolve
- Banks should review existing guidance and ensure appropriate controls are in pla

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