Analysis
Analysis: reassess whether vendor tiers reflect potential customer harm, financial exposure and substitutability. Less paperwork for a low-impact supplier should free capacity for dependencies that can interrupt servicing, move money or influence credit decisions.
What remains uncertain
The proposed guidance is non-binding , not a final regulation. Existing legal duties remain separate. The core-provider statement and proposed guidance are distinct documents with different scope.
Sources
- Federal Reserve — September 11 interagency announcement ↗Official release
- Federal Register — proposed third-party guidance, September 15 ↗Official source
- OCC Bulletin 2026-47 — core service providers ↗Official source