2023 Interagency Third-Party Risk Management Guidance

What the authority establishes

Joint supervisory guidance covering the full third-party relationship life cycle: planning, due diligence and selection, contract negotiation, ongoing monitoring, and termination. It emphasizes proportionality, governance, inventory, critical-activity identification, documentation, independent review, and oversight of subcontractors where appropriate.

It is the central cross-agency U.S. banking reference for designing and examining third-party risk programs. Product assessments should show how platforms support risk-based tiering, critical-activity oversight, lifecycle documentation, contract controls, ongoing monitoring, escalation, and termination.

The record is written for operational interpretation, not legal advice. Applicability depends on entity type, jurisdiction, relationship, service, data, criticality, contractual commitments, and later authority guidance.

Who should read it

The primary audiences named in this review are U.S. banks and banking organizations, bank boards and senior management, third-party risk and vendor-management teams, procurement, legal, compliance, cybersecurity, and internal-audit teams, fintech partnership and banking-as-a-service leaders. Those roles may divide responsibility differently, but the operating record should still show scope, accountable ownership, evidence, review, exceptions, and the final decision.

Third-party lifecycle implications

Governance And Oversight

Teams should determine what this authority expects at the governance and oversight stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Planning

Teams should determine what this authority expects at the planning stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Due Diligence And Selection

Teams should determine what this authority expects at the due diligence and selection stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Contract Negotiation

Teams should determine what this authority expects at the contract negotiation stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Ongoing Monitoring

Teams should determine what this authority expects at the ongoing monitoring stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Independent Review

Teams should determine what this authority expects at the independent review stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Termination

Teams should determine what this authority expects at the termination stage, which function owns the judgment, what evidence must be retained, and what later change would reopen the record.

Capabilities that may support the work

These links identify relevant operating capabilities; they do not state that any product creates compliance.

Intake And Inventory

establishing an accountable record of relationships, products, owners, and critical services. Buyers should test the workflow against their own scope and evidence requirements.

Inherent Risk Tiering

using relationship context to determine proportional diligence and review. Buyers should test the workflow against their own scope and evidence requirements.

Due Diligence And Assessments

collecting and reviewing evidence before and during a relationship. Buyers should test the workflow against their own scope and evidence requirements.

Evidence Collection

preserving source material, responses, and reviewer context. Buyers should test the workflow against their own scope and evidence requirements.

Continuous Monitoring

bringing material external and internal change into an owned response workflow. Buyers should test the workflow against their own scope and evidence requirements.

Issue Remediation

assigning findings, deadlines, exceptions, and closure evidence. Buyers should test the workflow against their own scope and evidence requirements.

Fourth-Party Visibility

identifying and explaining important downstream dependencies. Buyers should test the workflow against their own scope and evidence requirements.

Regulatory Mapping

connecting program records to obligations and examination needs. Buyers should test the workflow against their own scope and evidence requirements.

Reporting

turning program activity into operator, executive, and board-ready information. Buyers should test the workflow against their own scope and evidence requirements.

Offboarding

closing access, data, evidence, and residual obligations when a relationship ends. Buyers should test the workflow against their own scope and evidence requirements.

What software cannot decide

Software can structure records, route work, preserve evidence, surface change, and support reporting. It cannot determine legal applicability, set risk appetite, negotiate accountable contract terms, validate every external claim, accept residual risk, or make management responsible for an outcome. Those remain organizational decisions.