[Federal Register Volume 90, Number 227 (Friday, November 28, 2025)]
[Notices]
[Pages 54882-54886]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2025-21333]
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DEPARTMENT OF THE TREASURY
Office of the Comptroller of the Currency
[Docket ID OCC-2025-0537]
Request for Information Regarding Community Banks' Engagement
With Core Service Providers and Other Essential Third-Party Service
Providers
AGENCY: Office of the Comptroller of the Currency (OCC), Treasury.
ACTION: Request for information and comment.
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SUMMARY: The OCC is issuing a request for information (RFI) on
community bank engagement with their core service providers and other
essential third-party service providers. The RFI seeks to better
understand how challenges community banks face with such service
providers affect these banks' abilities to remain competitive in a
rapidly evolving marketplace, as well as what actions the OCC can take
to address any of these challenges.
DATES: Comments must be received by January 27, 2026.
ADDRESSES: Commenters are encouraged to submit comments through the
Federal eRulemaking Portal. Please use the title ``Request for
Information Regarding Community Banks' Engagement with Core Service
Providers and Other Essential Third-Party Service Providers'' to
facilitate the organization and distribution of the comments. You may
submit comments by any of the following methods:
Federal eRulemaking Portal--Regulations.gov:
Go to https://regulations.gov/. Enter Docket ID ``OCC-2025-0537''
in the Search Box and click ``Search.'' Public comments can be
submitted via the ``Comment'' box below the displayed document
information or by clicking on the document title and then clicking the
``Comment'' box on the top-left side of the screen. For help with
submitting effective comments, please click on ``Commenter's
Checklist.'' For assistance with the Regulations.gov site, please call
1-866-498-2945 (toll free) Monday-Friday, 9 a.m.-5 p.m. EST, or email
[email protected].
Mail: Chief Counsel's Office, Attention: Comment
Processing, Office of the Comptroller of the Currency, 400 7th Street
SW, Suite 3E-218, Washington, DC 20219.
Hand Delivery/Courier: 400 7th Street SW, Suite 3E-218,
Washington, DC 20219.
Instructions: You must include ``OCC'' as the agency name and
Docket ID ``OCC-2025-0537'' in your comment. In general, the OCC will
enter all comments received into the docket and publish the comments on
the Regulations.gov website without change, including any business or
personal information provided such as name and address information,
email addresses, or phone numbers. Comments received, including
attachments and other supporting materials, are part of the public
record and subject to public disclosure. Do not include any information
in your comment or supporting materials that you consider confidential
or inappropriate for public disclosure.
You may review comments and other related materials that pertain to
this action by the following method:
Viewing Comments Electronically--Regulations.gov:
Go to https://regulations.gov/. Enter Docket ID ``OCC-2025-0537''
in the Search Box and click ``Search.'' Click on the ``Dockets'' tab
and then the document's title. After clicking the document's title,
click the ``Browse All Comments'' tab. Comments can be viewed and
filtered by clicking on the ``Sort By'' drop-down on the right side of
the screen or the ``Refine Comments Results'' options on the left side
of the screen. Supporting materials can be viewed by clicking on the
``Browse Documents'' tab. Click on the ``Sort By'' drop-down on the
right side of the screen or the ``Refine Results'' options on the left
side of the screen checking the ``Supporting & Related Material''
checkbox. For assistance with the Regulations.gov site, please call 1-
866-498-2945 (toll free) Monday-Friday, 9 a.m.-5 p.m. EST, or email
[email protected].
The docket may be viewed after the close of the comment period in
the same manner as during the comment period.
FOR FURTHER INFORMATION CONTACT: Daniel Amodeo, Counsel and Graham
Bannon, Counsel, Chief Counsel's Office, 202-649-5490. If you are deaf,
hard of hearing, or have a speech disability, please dial 7-1-1 to
access telecommunications relay services.
SUPPLEMENTARY INFORMATION:
I. Introduction
Community banks \1\ have an outsized impact on lending and are
vital to the strength of the U.S. economy. The OCC has committed to
prioritizing reforms targeted at reducing the supervisory and
regulatory burden for community banks and exploring efforts to tailor
our regulation and supervisory frameworks to better fit their business
models and unique risks--better positioning these banks to support
their communities and drive economic growth. Many community banks are
dependent on third parties to operate effectively and competitively in
an increasingly online marketplace. This includes those third parties
that provide the comprehensive back-end applications and infrastructure
that support the operation and essential functions of one or more of
the bank's lines of business, including, for example, through the
provision of transaction processing, account management, payments
processing, customer relationship management, compliance and reporting,
online banking, and other material functions (core service providers).
It also includes those third parties who provide other essential
functions supporting those core functions, including cloud processing,
cloud storage, artificial intelligence, and compliance tools.
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\1\ The term ``banks'' as used in this RFI means national banks
and Federal savings associations.
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The OCC is aware that continued consolidation in the core service
provider and other essential third-party service provider markets can
result in reduced competitive pressure to provide innovative and
effective solutions for community banks; reduced negotiating power for
many community banks vis-[agrave]-vis their core service providers,
resulting in potentially burdensome contractual provisions and bundled
products that raise fees; and a sense that many community banks do not
believe that their core service providers and other essential third-
party service providers are partners committed to their long-term
success. According to one survey, for example, the three largest core
service providers served more than 70% of depository institutions in
2022, with the largest core service provider alone serving 42% of
depository institutions.\2\ At the same time, the OCC is aware that
many of these same banks believe these potentially anti-competitive
forces are
[[Page 54883]]
preventing them from taking full advantage of the rapid pace of
innovation in the financial technology marketplace, leaving them
exposed to changing consumer expectations they may not be able to meet.
Polling by community bank trade groups continues to show high levels of
dissatisfaction with core service providers--one recent poll showed
that, on a scale of 1 to 5, respondent depository institutions reported
an overall satisfaction level of 3.19 and rated the effectiveness of
their core service providers at 2.78, with certain of the largest core
service providers and their products consistently receiving lower
scores than many of their smaller peers.\3\ While financial technology
firms, new core service provider entrants, and bank-developed core
services have attempted to break into the market and address these
concerns, the increasingly high capital costs associated with switching
core service providers or other essential third-party service providers
or developing technological solutions in-house prevent many community
banks benefiting from these developments.
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\2\ See Julian Alcazar, et al., Federal Reserve Bank of Kansas
City, Payments System Research Briefing, ``Market Structure of Core
Banking Services Providers'' (Mar. 27, 2024), available at: https://www.kansascityfed.org/documents/10072/PaymentsSystemResearchBriefing24AlcazarBairdCronenwethHayashiIsaacson0327.pdf.
\3\ See American Bankers Association, ``2024 ABA Core Platforms
Survey: All Core Platform Providers Are Not the Same'' (Feb. 2025),
available at: https://www.aba.com/-/media/documents/reference-and-guides/2024-core-platform-survey.pdf?rev=f282f2c8fa1048dc8ab157ff8d9855ac.
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The OCC seeks public comment on community banks' engagement with
their core service providers and other essential third-party service
providers, especially as it relates to community banks' ability to
remain competitive in a rapidly evolving marketplace. The OCC also
welcomes comment on any aspect of other third-party service provider
activities, relationships, or supervisory or regulatory burdens insofar
as they relate to core service providers and other essential third-
party service providers. This includes whether and to what extent any
of the agency's supervisory guidance or regulatory requirements may
exacerbate the concerns described in this RFI or otherwise impose undue
burdens on community banks in managing their relationships with their
core service providers and other essential third-party service
providers.\4\ This RFI is designed to supplement the agency's
understanding of the challenges community banks face in their
relationships with these service providers and help the agency develop
a roadmap for supervisory and regulatory actions to consider these
concerns.
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\4\ Including, for example, the Interagency Guidance on Third-
Party Relationships: Risk Management. See 88 FR 37920 (June 9, 2023)
(TPRM Guidance).
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II. Background
This RFI stems from commenters' concerns noted in response to the
OCC's May 12, 2025, Request for Information Regarding Community Bank
Digitalization.\5\ The OCC received 22 comments from community banks,
industry groups, technology providers, and other interested parties.
Although focused on the use of technology to change a business model,
provide new revenue and value-producing opportunities, or automate
business processes, the agency also received numerous and varied
comments on community banks' relationships with their core service
providers and other essential third-party service providers. Some of
these commenters expressed concerns about predominant market reliance
on the largest core service providers, resulting in reduced bargaining
power and difficulty integrating new technology with legacy platforms
for community banks.\6\
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\5\ 90 FR 20212 (May 12, 2025).
\6\ In addition to comments on core service providers and other
third-party service providers, the OCC also received comments
broadly along the lines of the following two themes:
Resource Constraints: Commenters noted community banks'
difficulties in attracting and retaining sufficient staff with the
requisite skills to undertake modernizing digitalization projects,
as well as budget limitations and concerns around managing existing
technology debt.
Regulatory Clarity: Commenters suggested various ways
that the agency could improve regulatory clarity to reduce burden on
community banks, including that the agency consider establishing
sandboxes, pilot programs, or safe harbors related to digitalization
activities; engage in public-private dialogues and knowledge
exchanges; and issue no-action letters, reinstitute certain FAQs,
revise existing guidance (in particular, the TPRM Guidance), or
publish range-of-practice or lessons-learned documents expressing
observations on leading and lagging practices.
The OCC continues to review these comments to identify and craft
responsive actions to support community banks' digitalization
efforts.
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To better understand these comments and create a detailed record to
support potential agency action, the OCC conducted informal outreach
with various community banks. Broadly speaking, these community banks
identified the following concerns with certain core service providers
and other essential third-party service providers that they had either
experienced or else were concerned could limit their bank's ability to
remain competitive:
insufficient investment in innovation to ensure services
are keeping pace with market developments and perceived long
development timelines for new services;
use of dated programming languages leading to difficulties
integrating the services of acquired companies into a comprehensive,
unified package and posing interoperability with other third-party
service providers;
limitations on the use of unaffiliated third parties;
limitations on, and fees related to, accessing and
leveraging bank-owned data, including in a format that is comprehensive
and compatible with modern operating systems;
use of non-disclosure agreements that impede the free flow
of information on core service providers' pricing, services, and
contract terms;
bundling of unnecessary supplemental services leading to
increased fees (though some banks also acknowledged that lengthened
terms may result in lower prices);
costs and limitations surrounding service terminations and
core conversions (though some banks noted that termination fees may be
somewhat offset by buyouts from rival core service providers), together
with increased contract term lengths; and
overly lengthy and confusing billing practices requiring
significant manhours to catch repeated billing errors.
Several community banks also noted positive relationships with
certain specific core service providers. These community banks noted
that such core service providers treat the arrangement as a long-term
relationship, allow and encourage their customer banks to submit
requests as to desired new services, provide application program
interfaces (APIs) with limited restrictions that allow unaffiliated
third-party service providers to seamlessly plug into the core service
provider's platform, and maintain data in up-to-date formats.
Community banks that participated in these listening sessions
almost unanimously voiced concerns about the ability of their core
service providers to supply community banks, on a timely basis, with
the products, services, and solutions they need to remain competitive
in a rapidly evolving marketplace, particularly with regard to the
growing stablecoin and crypto-asset markets and to changes to the
banking industry that may accompany recent and ongoing developments in
artificial intelligence.
The OCC also notes that the Financial Stability Oversight Council
has also repeatedly noted similar concerns and has supported the
Federal banking agencies and other agencies addressing the risks that
core service providers and other essential third-party service
providers pose to financial institutions
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that could spread and undermine financial stability.\7\
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\7\ See, e.g., Financial Stability Oversight Council, 2024
Annual Report (Dec. 6, 2024) at 88 (``Smaller firms, such as
community banks and credit unions, may have lesser negotiating power
to obtain certain contractual rights, fewer resources and ability to
conduct due diligence on and monitor a service provider's practices
(e.g., information security, internal controls, assurance testing),
and lesser ability to terminate and substitute services in case of
operational challenges. And yet, due to their relatively small size,
these institutions are increasingly relying on third parties for
essential lending, compliance, technology, and operational-related
matters. Regulators and market participants alike can have low
visibility into the use of common third-party service providers by
financial institutions, or even the geographic location for the
delivery of services. This opacity can make it difficult to prepare
for, and rapidly evaluate the impact of, a cyber incident or other
disruption at a third-party service provider or in a geographic
location (such as a regional outage).'').
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III. Questions
The OCC notes that it is vital for U.S. economic security that
community banks be able to remain competitive in a rapidly evolving
marketplace. As such, the OCC is seeking further information on any
barriers community banks face in remaining competitive and any
responsive actions that the agency could take. The agency also reminds
core service providers and other essential third-party service
providers that certain services they perform for a bank are subject to
regulation and examination by the agency to the same extent as if such
services were being performed by a client bank itself on its own
premises.\8\
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\8\ See 12 U.S.C. 1867(c). Additionally, the OCC is concerned
about the reported prevalence of billing errors, as well as the use
of overly-complicated and lengthy billing statements that require
considerable bank resources to understand and review. Billing for a
service is an inherent component of performing a bank service and
may be subject to supervision and regulation. The agency also notes
that billing errors may expose core service providers to contractual
liability and could constitute a violation of law.
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The OCC seeks input from community banks, industry groups, service
providers, and other interested parties regarding the challenges and
barriers in all aspects of community banks' relationships with their
core service providers and other essential third-party service
providers. These may include challenges and barriers related to:
contract negotiations;
the scope and burden of applicable fees;
billing practices and concerns;
oversight of core service providers and other third-party
service providers;
the ability to terminate relationships with core service
providers in breach of contracts, including service-level agreements;
any burdens limiting banks' ability to undertake core
conversions that are beyond those inherent in such a process;
the extent to which interoperability between core service
providers and other third-party service providers may facilitate or
inhibit innovations necessary for community banks to remain competitive
in a rapidly evolving marketplace;
supervisory expectations and guidance, including the Third
Party Risk Management (TPRM) Guidance, or regulatory requirements; and
potential actions the OCC could take to address these
concerns and other relevant topics.
In addition, we invite the relevant stakeholder to respond to the
following specific questions:
Innovation
1. What challenges have community banks faced, or do they expect to
face, in relation to their core service providers and other essential
third-party service providers in implementing innovative solutions or
accessing services necessary for community banks to remain competitive
in a rapidly evolving marketplace? What are examples where a bank
believes its service providers have been able or unable to provide
innovative solutions and adaptations, and what lessons can be learned
from such experiences?
2. What challenges have community banks faced, or do they expect to
face, in relation to their core service providers and other essential
third-party service providers in responding to the growing stablecoin
and crypto-asset markets? How might the OCC address those concerns
through regulatory and supervisory authority? How might the exercise of
OCC regulatory or supervisory authority complicate challenges community
banks face in this area?
3. What challenges have community banks faced, or do they expect to
face, in relation to their core service providers and other essential
third-party service providers in responding to developments in
artificial intelligence? How might the OCC address those concerns
through regulatory and supervisory authority? How might the exercise of
OCC regulatory or supervisory authority complicate challenges community
banks face in this area?
4. What challenges do community banks face in verifying the
feasibility and effectiveness of innovative solutions offered or
marketed by core service providers and other essential third-party
service providers, or otherwise achieving visibility into such
solutions? How do community banks ensure that the innovative solutions
offered by these service providers truly meet their operational and
strategic needs?
5. What challenges do community banks face in ensuring the
availability and quality of post-implementation support from core
service providers and other essential third-party service providers?
6. What challenges do community banks face in assessing the
scalability and flexibility of core service providers' and other
essential third-party service providers' solutions to ensure they can
grow with the bank's needs?
7. What challenges do community banks face when they decide to
extract and leverage their data maintained by providers for modernized
technology solutions? Are there any steps that the OCC could take to
help ease or incentivize the process? For example, are community banks
concerned that they may face increased regulatory scrutiny if they seek
to convert their data? Alternatively, are there specific examples of
regulatory relief, safe-harbors, or tailoring that the OCC could
provide that may help community banks offset the capital costs of doing
so?
8. Are there specific tools or training that the OCC could provide
or facilitate to assist community bankers in developing their
technological expertise to better manage innovation, whether internally
or in managing their core service provider or other essential third-
party service provider relationships?
9. Are there actions that the OCC could or should take to
facilitate community banks in developing their own technology
solutions? For example, are there actions that the OCC should consider
to encourage and enable community banks to pursue joint ventures or to
invest in subsidiaries for the purpose of developing their own
innovative technology solutions?
10. What have been community banks' experiences and challenges
concerning the ability to connect different third-party or in-house
solutions with their core service provider? What barriers do community
banks face when trying to establish API requests between core service
providers and other service providers? How might the OCC address these
barriers?
11. What cyber security related challenges do community banks face
in connection with service providers and API requests? How do those
challenges impact the ability to scale business? How do core service
providers enable community banks to provide secure services, including
where the bank provides services through or in connection with a non-
core service
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provider third-party? How might the OCC address these challenges or
further support core service providers enabling the provision of secure
services?
Due Diligence & Transparency
12. To what extent could some of the concerns voiced by community
banks discussed in this RFI be addressed by the OCC establishing a
publicly searchable database related to banks' experiences with core
service providers and other essential third-party service providers,
including, for example, as to complaints? For example, to what extent
could the existence of such a database assist community banks in
performing due diligence in selecting a core service provider or other
essential third-party service provider that best meets their business
needs? To what extent would such a database be likely to incentivize
core service providers and other essential third-party service
providers to increase transparency as to opaque pricing or contracting
practices or to ensure billing accuracy?
13. To what extent could some of the concerns raised in this RFI be
addressed by the OCC proactively sharing with community banks certain
information on core service providers and other essential service
providers, including on the terms of the services they perform? What
information would community banks find helpful in the planning, due
diligence and third-party selection, contract negotiation, ongoing
monitoring, or termination phases of the third-party risk management
cycle? How should any publication be balanced against, and what steps
should the agency consider regarding, the potential confidentiality of
any such data or data security concerns (e.g., conditioning the
provision of such data on non-disclosure agreements and the use of
secure, read-only software)?
14. As an example of the above, to what extent would it assist
community banks with contract negotiations if the OCC were to explore
the feasibility of developing a ``registry'' system in which core
service providers and other essential third-party service providers
would be required to provide certain information to the OCC and if some
or all of this information were then made available to community banks?
For example, the registry system could be premised on such service
providers ensuring, on a recurring basis, that their notifications to
the OCC about service relationships with OCC-regulated banks remain
current and include the terms of the performance of the associated
services and the use of certain terms and conditions in contracts. What
considerations should the OCC evaluate if it were to adopt this
approach?
15. What should constitute fair contracting terms for core service
provider and other essential third-party service provider contracts
with community banks? How might the OCC help ensure that such service
provider agreements provide equal access to financial services,
including fair treatment of community banks as customers of service
providers? Should the OCC explore the feasibility of certifying whether
service providers include fair contracting terms in their service
agreements? What considerations should the OCC evaluate if it were to
adopt this approach?
16. What challenges do community banks face when seeking to assess
the financial condition of potential core service providers and other
essential third-party service providers? Is there nonpublic financial
information community banks believe they need to evaluate the long-term
viability of such service providers? Are community banks able to
negotiate access to relevant financial information of such a service
provider as part of the contract deliberation process? How might the
OCC assist community banks in obtaining relevant financial information
to make informed decisions about engaging such service providers?
17. Should the OCC consider exploring ways to make applicable core
service provider and other essential third-party service provider
reports of examination (ROEs) (or targeted information obtained from
the ROEs) accessible to OCC-regulated banks as they are conducting
their due diligence into such service providers, before a contract is
executed? To what extent would providing community banks with access to
the open portion of such historical ROEs or else the latest ROEs for
applicable core service providers or other essential third-party
service providers give banks additional insight into whether such
service providers adequately meet the banks' needs before entering into
a contractual relationship? How might the provision of such ROEs to
community banks impact the service provider market and the availability
of services for community banks? What steps should the agency consider
regarding the confidentiality of any such data or data security
concerns (e.g., conditioning the provision of such data on non-
disclosure agreements and the use of secure, read-only software)? What
other concerns should the agency consider in operationalizing such a
process?
18. To what extent do community banks utilize the ROEs for core
service providers or other essential third-party service providers with
whom they have an ongoing contractual relationship as a data point in
their ongoing monitoring of such service providers? Are there any
challenges in using ROEs that the OCC should consider addressing (e.g.,
the frequency with which ROEs are issued or the content that is
accessible for banks to review)? What other mechanisms should the OCC
consider by which it could inform community banks about concerns
related to specific core service providers or other essential third-
party service providers?
Reducing Supervisory and Regulatory Burden
19. To what extent do current supervisory practices, policies, or
guidance or the agency's regulations present challenges or undue
burdens to community banks in managing and overseeing their core
service provider relationship or in undertaking a core conversion? For
example, are there elements of either the TPRM Guidance \9\ or the
OCC's Third-Party Risk Management: A Guide for Community Banks \10\
that community banks believe to be overly prescriptive or not
sufficiently clarified as being a tool to help banks assess and manage
risks through practices tailored to the degree of risk present, or that
community banks have experienced examiners using in a prescriptive,
non-risk-based manner? Alternatively, to what extent would community
banks benefit from additional supervisory or regulatory clarity?
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\9\ The OCC reiterates that the TPRM Guidance is intended to be
a principles-based tool for banks to assess and manage their risks
from third parties. It is not a prescriptive requirement and a
bank's third-party risk management should be tailored to the bank's
size, complexity, and risk profile and to the nature of its third-
party relationships. See also 12 CFR part 4, subpart F (Use of
Supervisory Guidance).
\10\ May 2024, available at: https://www.occ.gov/news-issuances/news-releases/2024/pub-third-party-risk-management-guide-for-community-banks.pdf.
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20. To what extent has supervisory scrutiny prevented a community
bank from undergoing a core conversion or in some other manner
modernizing or leveraging data for innovative solutions, or materially
increased the burden on a community bank going through such a process?
Are there examples of supervisory or regulatory reform, tailoring, or
safe harbors that could allow the agency to better facilitate core
conversions or data ownership and modernization that a community bank
believes is in the best interest of its business while not downplaying
the
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safety and soundness risks inherent in such practices?
Costs
21. How has the cost of contracting with core service providers or
other essential third-party service providers evolved over the last ten
years? How have these changes impacted the ability of community banks
to modernize operations? How can such service providers and community
banks address challenges posed by rising costs? What role might the OCC
be able to serve in addressing concerns and challenges posed by costs?
22. To what extent have costs prevented conversions or impacted the
abilities of community banks to modernize operations? Are such costs
imposed by service providers, related to internal factors (e.g.,
deficiencies in staffing resources or expertise), or due to supervisory
or regulatory scrutiny or requirements? What role might the OCC be able
to serve in addressing these concerns?
23. How would any of the policies contemplated in this RFI affect
costs and the availability of services from core service providers and
other essential third-party service providers?
24. What data should community banks, core service providers and
other essential third-party service providers, or the OCC consider when
evaluating such service providers' costs?
25. To what extent has a service provider's systems or operations
created legal risk or caused any violations of laws or regulations for
the bank?
Billing Statements and Errors
26. To what extent are community banks able to timely and
effectively review billing statements from core service providers or
other essential third-party service providers? What challenges do
community banks face in reviewing these billing statements, including
as to length and complexity? What resources do community banks need to
dedicate to reviewing these billing statements?
27. To what extent have community banks experienced errors in core
service providers' or other essential third-party service providers'
billing statements? What is the average frequency and what are the
average dollar values (including in absolute terms and as a percentage
of the entire bill) of any such errors? What is the impact of such
errors on the bank?
28. How might the OCC (together with the Board of Governors of the
Federal Reserve System and the Federal Deposit Insurance Corporation,
as part of their joint service provider examinations) better reflect
the prevalence of core service providers' or other essential third-
party service providers' billing practices and errors in any applicable
service providers' examination ratings?
29. To what extent would a database (discussed in Question 12
above) help address the prevalence of any such billing errors?
30. To what extent would guidance on core service provider and
other essential third-party service provider billing and fee best
practices and supervisory expectations help address the prevalence of
any such billing errors?
31. What other actions should the OCC consider taking in addressing
any prevalent billing errors?
Facilitating Community Bank and Service Provider Dialogue
32. Prior to the pandemic, the OCC held annual meetings with
various core service provider and other essential third-party service
provider executives. To what extent would reviving those annual
meetings or otherwise establishing contact channels help facilitate the
sharing of community bank concerns with such service providers?
33. What would be the benefits and challenges of the OCC
facilitating community banks and other interested parties in
establishing ad hoc or standing groups that could work towards planning
and implementing private market solutions to any of the concerns
addressed in this RFI?
Jonathan V. Gould,
Comptroller of the Currency.
[FR Doc. 2025-21333 Filed 11-26-25; 8:45 am]
BILLING CODE 4810-33-P