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The draft guidance also covers supervisory considerations for third-party lending arrangements and outlines exam procedures. Comments on the draft guidance are due Sept. 12 and should be sent to firstname.lastname@example.org.
Read the draft guidance.