Written for the individual your credit union designates as responsible for coordinating and monitoring day-to-day compliance.
- Comments on the proposed third-party risk guidance close Monday, November 16. After that you can still raise it with your examiner, but not on the record.
- The proposal expressly defines “banking organization” to include insured credit unions. On the obligation, you are in, unambiguously.
- The lighter-inventory relief is offered to “a community bank.” The proposal never defines that term.
- So the sentence that binds you uses a defined word and the sentence that helps you uses an undefined one. That asymmetry is the comment.
- It is a short filing and a credit union is the right institution to make it, because the agencies cannot see the gap from where they sit.
What Issue 01 left open
Two weeks ago this newsletter covered the proposal and flagged that the streamlined-inventory language was offered to “a community bank” while the express definition ran to “banking organization.” That question is still open, the window is still open, and it closes Monday week.
Here is the asymmetry in the proposal’s own words. On who is covered:
“For purposes of this proposed guidance, banking organizations also include insured credit unions as defined in the Federal Credit Union Act (12 U.S.C. 1752(7)).”
And on the relief:
“For example, a large or complex banking organization with multiple higher-risk third-party relationships may benefit from a periodically updated and detailed inventory that maps individual subcomponents of a third-party relationship to various banking organization business units, reporting lines, or other accountability mechanisms, while a community bank may benefit from a simpler or streamlined format that allows its management to quickly assess relevant third-party relationships at a higher level.”
Read the two halves next to each other. The heavier expectation is keyed to risk — large or complex, multiple higher-risk relationships. The lighter one is keyed to an institution type the proposal never defines. The agencies took the trouble to define “banking organization” and did not do the same for the word carrying the relief, so the sentence changes footing halfway through: risk on one side, charter on the other.
Why this is a credit union’s comment to make
Nobody at the agencies is withholding the relief. The drafting reflects who the drafters pictured, and the fix is to say so while the record is open.
A comment letter does not need to be long and it does not need counsel. The ones that land name a specific sentence, say what it does at a specific institution, and propose wording. Three paragraphs is enough if all three are concrete.
I have watched the people with the most specific operational objection file last, or not at all — a specific objection takes work to write, and a generic one is easier to leave to a trade association. So the record fills with positions and thins where the agencies said they needed detail.
What to put in it
Name the sentence. Quote the streamlined-inventory example and the definitional sentence next to each other. The asymmetry does the work; you do not need to characterize it.
Say what it does at your shop. One concrete consequence — the inventory you maintain today, the number of relationships in it, what a detailed subcomponent mapping would cost you in hours. A figure from your own institution is the thing no trade association can supply.
Propose the wording. Ask that the example use a defined term, or that the agencies define “community bank,” or that the relief be keyed to the risk profile the proposal itself uses everywhere else. Any of the three is a usable answer.
Where to file
Comments go to each agency separately, under its own docket. Credit unions file with the NCUA:
- NCUA — NCUA-2026-1684
- OCC — OCC-2026-0793
- Federal Reserve — OP-1881
- FDIC — 3064-ZA58
“Comments must be received on or before November 16, 2026.”
Sources
- Proposed Interagency Guidance on Third-Party Relationships: Risk Management — 91 FR 58536, published September 15, 2026; FR document 2026-18859. Dates, dockets, the definitional sentence and the inventory example all retrieved 2026-11-05.
If a comment is worth filing and nobody at your institution has the week to write it, that is work 7T World does with community banks and credit unions.
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