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Banks manage cybersecurity risks from third-party vendors by assessing each relationship according to its potential impact, gathering evidence about the provider’s security and resilience, setting clear contractual expectations, and monitoring performance throughout the relationship. The provider may perform the work, but the bank remains responsible for its own safe and sound operation and compliance with applicable law.
What U.S. banking guidance says—and what it does not
The Federal Reserve, FDIC, and OCC issued the Interagency Guidance on Third-Party Relationships: Risk Management on June 6, 2023. It sets out risk-management principles for the full life of a third-party relationship and replaced each agency’s earlier general third-party guidance. Its approach is tailored: oversight should reflect the bank and the particular relationship, with deeper and more comprehensive work for higher-risk relationships, including those supporting critical activities.
The guidance makes clear that outsourcing does not transfer the bank’s responsibilities: “A banking organization’s use of third parties does not diminish or remove a banking organization’s responsibility to meet these requirements to the same extent as if its activities were performed by the banking organization in-house.”
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The agencies’ 2024 Third-Party Risk Management: A Guide for Community Banks is a companion resource, not a binding rule or mandatory checklist. In a May 7, 2024 letter, the Federal Reserve said: “This guide does not have the force and effect of law and does not impose any new requirements on banking organizations.” The guide is voluntary and aimed at community banks, though it may be useful to other banks.
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As of October 2026, the OCC’s September 11, 2026 announcement of revised third-party-risk guidance is a proposal, not final guidance. Coordinated with the Federal Reserve, FDIC, and NCUA, it proposes tailoring practices to the reasonably assessed risk of each relationship and prioritizing according to the magnitude and likelihood of potential harm. The OCC says the proposed guidance would not establish enforceable standards or prescriptive requirements. Its comment period is 60 days from Federal Register publication; check the Federal Register for the publication date and deadline rather than assuming a calendar date. The OCC also announced an interagency statement concerning risk-based supervision of certain core-provider services to community banks; consult that statement for its specific factors.
How to decide which providers need the closest oversight
Begin with the service and the actual arrangement, not a generic vendor label. Map what the provider does, what systems and information it can reach, whether it processes transactions or interacts with customers, and which other providers or technologies the service depends on. Include subcontractors and shared technology where they affect the bank’s ability to deliver the service or protect information.
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Assess the possible consequences of a failure, compromise, or interruption. An activity may be critical when its failure could expose the bank to significant risk, materially affect customers, or significantly affect the bank’s financial condition or operations. Criticality depends on context: the same service may be critical for one bank and not another.
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What to check before trusting a technology provider
Due diligence should examine the provider’s information-security program and whether it can protect the confidentiality, integrity, and availability of the bank’s information and services. The following questions translate the agencies’ considerations into practical lines of inquiry; they are not a universal pass/fail checklist.
- Access and data: Which bank systems, customer information, or transaction flows can the provider access? How is access limited, authorized, and reviewed, including for the provider’s personnel and subcontractors?
- Security safeguards: What safeguards are in place, such as multifactor authentication, end-to-end encryption, and secure source-code management? Ask how they apply to the specific service and data involved.
- Threat and vulnerability management: How does the provider identify, assess, and mitigate known and emerging threats? Where relevant, review vulnerability assessments and penetration-test results, including the scope, material findings, and remediation status.
- Software, infrastructure, and data practices: For the service being considered, how are applications developed and secured, infrastructure protected, and data handled? Request evidence relevant to the bank’s use of the service rather than relying on broad assurances.
- Corrective action: What deficiencies have been identified, what is being done about them, and what evidence shows that corrections are effective and sustained? Unresolved or repeat findings warrant scrutiny proportionate to their severity and impact.
- Continuity and recovery: What business-continuity and disaster-recovery plans support the service? Establish the provider’s recovery time frames for activities and data, and examine test results or performance during actual disruptions where available.
Security evidence is only one part of due diligence. Depending on the service and its risk, also assess the provider’s financial condition, legal and regulatory compliance, experience, personnel, and broader risk management. A certification or a provider’s assurance alone does not establish that the service is suitable for the bank’s specific risk and control needs.
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How to manage the relationship from selection through exit
The 2023 interagency guidance describes five connected stages. Governance, accountability, independent review, documentation, and reporting support the work throughout; the process is continuous rather than a one-time vendor approval.
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|---|---|
| Planning | Define the business need, the provider’s role, relevant access and dependencies, and the risks of using the service. Determine whether the activity is critical in the bank’s context and what level of oversight is appropriate. |
| Due diligence and selection | Assess the provider’s ability to meet the bank’s needs, including security, resilience, financial condition, compliance, experience, and other relevant risks. Compare the evidence with the service’s expected risk and impact. |
| Contract negotiation | Translate the bank’s assessment into clear service expectations and workable arrangements for information access. Ensure the bank understands the provider’s systems, processes, and interdependencies relevant to the service. |
| Ongoing monitoring | Check that controls remain effective and sustainable and that the provider meets its commitments. Set the monitoring method and frequency according to the relationship’s risk, and escalate material changes or problems. |
| Termination | Plan how the bank would end or transition the relationship, including options if the provider can no longer perform. Consider dependencies and how the bank would maintain the service and protect or recover its information. |
During monitoring, indicators for escalation include material or repeat audit findings, provider financial deterioration, security breaches, data loss, service interruptions, and compliance lapses. Monitoring may be periodic or continuous; the appropriate depth and frequency depend on the relationship’s risk and the bank’s circumstances. Contractual commitments matter only if the bank can assess whether they are being met and respond when they are not.
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Why supply-chain exposure and resilience matter
The OCC’s Cybersecurity and Financial System Resilience Report 2025 says supply-chain risk continues to evolve as threat actors exploit vulnerabilities in IT systems and third-party software used by many organizations. This is the OCC’s supervisory assessment, not a bank incident-rate statistic. For bank oversight, the practical implication is to consider shared technology and provider dependencies alongside the security of the direct vendor, and to understand how the bank would continue operating if a provider or commonly used system were disrupted.
Concentration and exit options belong in that assessment. A provider may support multiple important services, or a service may depend on a small number of providers or technologies. Consider the potential effect of disruption, available alternatives, transition constraints, and the bank’s recovery arrangements. The aim is not to eliminate all third-party dependence, but to understand where a failure could have a larger effect and plan oversight accordingly.
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