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OCC Bulletin 2025-39 | November 24, 2025

Bank Activities: Request for Information on Community Banks’ Engagement with Core Service Providers and Other Essential Third-Party Service Providers

To

Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties

Summary

Today the Office of the Comptroller of the Currency (OCC) released a request for information (RFI) on community banks’ engagement with their core service providers and other essential third-party service providers.

Note for Community Banks

This request for information applies to all banks that may want to comment on the matters in the RFI.

Highlights

The RFI solicits comments on the key challenges and barriers faced by community banks in engaging with their core service providers and other essential third-party service providers. The RFI focuses on ensuring that community banks can remain competitive in a rapidly evolving marketplace, and includes questions on the challenges community banks face related to contract negotiations and terms, fees, billing practices, oversight, due diligence, innovation, core conversions, data access and modernization, and interoperability issues. It also includes questions on potential actions the OCC could take to address these challenges, including with respect to burden reduction related to supervisory practices, policies, and guidance (e.g., guidance on third-party risk management), as well as other potential agency initiatives.

The RFI is not intended to impose any obligations or define any rights, and it is not an interpretation of any regulation or statute. The OCC’s mission is to ensure that national banks and federal savings associations operate in a safe and sound manner, provide fair access to financial services, treat customers fairly, and comply with applicable laws and regulations.

Comments must be received within 60 days of publication in the Federal Register.

Further Information

Please contact Daniel Amodeo, Counsel or Graham Bannon, Counsel, Chief Counsel’s Office, 202-649-5490.

 

Adam Cohen
Senior Deputy Comptroller and Chief Counsel

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