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Tuesday, August 2, 2016

FDIC Issues Draft Guidance on Third-Party Lending

The FDIC board has voted to issue examination guidance for third-party lending. The term encompasses any involvement of a third party in any part of the lending process, including marketing, underwriting, pricing, servicing, disclosures, compliance, collection and other areas – whether the FDIC-insured institution originates a loan on behalf of a third party, uses a third party’s platform or originates a loan through or jointly with a third party.

The exam guidance supplements the FDIC’s existing guidance on third-party risk management and covers strategic, operational, credit and compliance risks associated with third-party lending. It also covers the basic elements of an effective third-party lending risk management program, including risk assessment, due diligence, contract structuring and oversight.

The draft guidance also covers supervisory considerations for third-party lending arrangements and outlines exam procedures. Comments on the draft guidance are due Sept. 12 and should be sent to thirdpartylending@fdic.gov.

Read the draft guidance.

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