No one benefits when banks and their potential partners or other vendors have to navigate unnecessary differences in guidance between agencies. To that end, the Federal Reserve is in the process of working with the other banking agencies to update our third-party guidance.
As part of this process, I believe that the banking agencies should all have consistent expectations for third-party  - 12 relationships, and that the Federal Reserve should, as a starting point, move toward adopting the Office of the Comptroller of the Currency’s guidance. Third, I believe we can improve transparency with regard to our supervision of third parties.