Joint Trades Request Extension of Comment Due Date for Third-Party Risk Management Proposals

To Whom It May Concern:

On September 15, 2026, the Federal Deposit Insurance Corporation, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the National Credit Union Administration (collectively, "the Agencies") requested comment on proposed revisions to the Interagency Third-Party Risk Management Guidance ("Interagency Proposal"). That same day, the Federal Reserve also requested comment on its Proposed Third-Party Risk Management Guidance for Community Bank Organizations ("Federal Reserve Proposal"). Comments on both proposals are due on November 16, 2026. The undersigned trade associations respectfully request a 30-day extension of these comment periods.

The proposals contain several helpful elements, such as a more focused scope and an emphasis on risk-based tailoring. However, initial feedback from bankers representing institutions of all sizes has included observations that warrant additional discussion and analysis. In particular, members have raised questions regarding how the proposed approach could affect due diligence and contracting in practice. In addition, third-party risk management guidance and policy impact a number of risk disciplines within each banking organization, including cybersecurity, resilience, privacy, and compliance, among others. Additional time would allow our associations to engage in more thorough discussions with our members to formulate constructive comments on the proposals.

In addition, some of the undersigned associations intend to comment on both the Interagency Proposal as well as the Federal Reserve Proposal, which are due on the same day. An extension would help those associations and their members fully consider how the two proposals would interact and whether they would operate as intended. The timing of these proposals also comes amid a particularly active regulatory agenda that has required banks and trade associations to devote substantial resources to multiple significant regulatory matters. In light of these competing demands, a modest extension would provide the time necessary to undertake a careful analysis of both proposals and provide the Agencies with more fulsome comments.

Thank you for considering this request.

Sincerely,

American Bankers Association
Bank Policy Institute
Consumer Bankers Association
Independent Community Bankers Association