Unknown Sponsor Bank

The OCC, Federal Reserve, and FDIC jointly issued revised interagency guidance on model risk management on April 17, 2026. The guidance specifically addresses vendor and third-party products, which directly impacts how banks manage models provided by fintech partners in BaaS arrangements.

Banks relying on third-party fintech vendors for credit decisioning, fraud detection, or other model-driven products are expected to maintain robust model risk management practices. This updated guidance signals continued supervisory attention to the risks that arise when banks outsource or rely on fintech-provided models without adequate oversight.