The Clearing House Association and The Clearing House Payments Company (collectively, TCH) submitted a comment letter to the FDIC in response to the FDIC’s request for information (RFI), titled “Request for Information on Standard Setting and Voluntary Certification for Models and Third-Party Providers of Technology and Other Services.” TCH submitted comments to ensure that the FDIC is aware of developments in the area of data sharing with customer permissioned third-parties (commonly known as “data aggregators”) as they pertain to aspects of the work that the FDIC is considering. TCH also noted that the frameworks that have and are being developed to address third-party risk management in the data aggregation space may inform how the industry and regulators might approach the management, assessment and oversight of third-party model deployment from a fintech into the financial institution ecosystem. TCH’s comment letter describes industry developments and current practices that address third-party risk management in the data aggregation space, including the development of standard setting and certification frameworks. TCH urged the FDIC to ensure that any further work it undertakes in relation to the development of standards and certifications, and third-party risk management, fully align with work that is already taking place in the industry. TCH also encouraged the FDIC to coordinate with other financial institution regulators in order to avoid the development of a bifurcated approach that could create inefficiencies in the market and inhibit industry solutions from reaching scale.
To read the full comment letter click here.