OCC Bulletin 2013-29 — National Banks & Federal Savings Associations

OCC Third-Party Risk Management:
Examiner-Ready Evidence at $49/month

OCC Bulletin 2013-29 requires national banks to manage third-party relationships across the full lifecycle — due diligence, ongoing monitoring, and documented oversight for critical activities. VendorAuditly automates OCC-aligned vendor assessments and generates examiner-ready evidence packs without a dedicated compliance team.

What OCC Bulletin 2013-29 requires
OCC Bulletin 2013-29 requires national banks and federal savings associations to maintain a risk management programme for all third-party relationships throughout their lifecycle. This means a documented vendor inventory, pre-engagement due diligence, written contracts with required provisions, ongoing monitoring with evidence, and enhanced oversight for critical activities. OCC examiners expect to see systematic, documented evidence — not spreadsheets and emails.

OCC Bulletin 2013-29

What OCC third-party risk management requires

OCC Bulletin 2013-29 (supplemented by interagency guidance in 2021 and 2023) sets out a lifecycle framework for managing third-party relationships. The framework applies to all OCC-supervised institutions — national banks and federal savings associations.

Phase 1 — Planning

Risk assessment before engagement

Before entering a third-party relationship, banks must assess the risks posed by the activity and the proposed provider. For critical activities, this includes a formal business case, risk assessment, and due diligence plan. OCC examiners expect to see this documented before contract execution.

Phase 2 — Due Diligence

Documented pre-contract assessment

Due diligence depth scales with the risk and criticality of the activity. For critical activities, banks must assess financial condition, business experience, risk management practices, information security, business continuity, and sub-contractor reliance. Evidence of completion must be on file.

Critical activities require enhanced due diligence
Phase 3 — Contracts

Required contract provisions

OCC-supervised banks must ensure third-party contracts include: scope of arrangement, performance standards, audit rights, regulatory access, sub-contracting controls, data security requirements, business continuity obligations, and termination provisions. Missing provisions are a common examiner finding.

Phase 4 — Ongoing Monitoring

Evidence that monitoring happened

Banks must monitor third-party performance against contract standards throughout the relationship. For critical activities, this includes periodic reviews, tracking of SOC reports, financial statements, incidents, and complaints. The evidence of monitoring matters as much as the monitoring itself.

Phase 5 — Termination

Documented exit and transition

Banks must maintain termination plans for critical activities that address data return, transition timelines, and business continuity during the exit. OCC examiners check whether banks can exit critical third-party relationships without operational disruption.


Enhanced scrutiny

Critical activities — where OCC examiners focus

OCC Bulletin 2013-29 identifies “critical activities” as third-party relationships that warrant heightened due diligence and more frequent monitoring. These are the relationships OCC examiners sample first.

Critical activity criteria

What makes a third-party relationship a “critical activity”

A relationship is a critical activity if it involves: significant bank functions (e.g. core banking, payments, technology infrastructure), contains sensitive customer information, has significant customer impact if it fails, or relies on a provider that is difficult to replace quickly. Banks must formally document which relationships are critical.

Examiner expectation

What examiners look for in critical activity oversight

For critical activities, OCC examiners expect: board-level awareness and approval, dedicated relationship owners, documented due diligence with evidence, periodic review reports (annual minimum), sub-contractor mapping, and formal contingency and exit planning. The absence of any of these for a critical activity is a likely examiner finding.

Common finding: monitoring documented in policy but not evidenced in practice
Fourth-party risk

OCC requires oversight of your vendors’ sub-contractors

OCC Bulletin 2013-29 requires banks to understand and manage the risk from their critical providers’ own sub-contractors. Banks must ensure their contracts allow them to receive information about material sub-contractors and that critical providers have appropriate sub-contractor oversight programmes.

2023 interagency guidance

Alignment with Federal Reserve and FDIC

In June 2023, the OCC, Federal Reserve, and FDIC issued joint guidance aligning their third-party risk expectations across US banking regulators. The guidance reinforces the OCC Bulletin 2013-29 lifecycle framework and clarifies that all banks — including community banks — are expected to have a risk-based programme proportionate to their size and complexity.


How VendorAuditly helps

OCC-aligned vendor risk management — without a compliance team

VendorAuditly automates the OCC third-party risk management lifecycle for community banks and OCC-supervised institutions that don’t have a dedicated compliance function.

1

Third-party register with risk classification

Maintain a complete, live inventory of all third-party relationships with risk tier classification (Critical, High, Medium, Low), relationship owner, data access level, and contract dates. OCC examiners can see at a glance that your inventory is current and systematically classified.

2

Pre-engagement due diligence questionnaires

Send vendors security questionnaires covering information security practices, business continuity plans, sub-contractor reliance, and data handling. Questionnaire responses are timestamped and stored per vendor — documenting that due diligence was completed before contract execution.

  • SOC 2 security assessment template
  • FFIEC-aligned IT security questionnaire
  • Business continuity and resilience template
  • Data processing and GLBA compliance template
3

Contract tracking with required provisions flag

Track contract expiry dates, renewal terms, and AI-assisted contract clause analysis. VendorAuditly flags missing provisions required by OCC guidance — including audit rights, regulatory access, data security requirements, and sub-contractor controls — so gaps are caught before an examiner does.

4

Ongoing monitoring with dated evidence

VendorAuditly runs continuous monitoring across all vendors: live risk score recalculation, breach watchlist screening (HIBP + CISA KEV), and website availability monitoring. Every monitoring event is timestamped, giving examiners a dated evidence trail that monitoring happened — not just that a policy says it should.

5

Examiner-ready evidence pack in one click

Generate a complete evidence pack covering your entire third-party register: vendor inventory, risk classifications, due diligence records, contract status, certificate tracking, and monitoring history. Structured, dated, and ready to present at an OCC examination without additional preparation.


What OCC examiners see

Spreadsheets vs. VendorAuditly — the examiner’s view

Most community banks manage third-party risk in spreadsheets and email threads. OCC examiners can tell. VendorAuditly gives examiners what they expect to see: a systematic, documented, dated programme.

📋
Spreadsheets & email
How most SMBs manage vendor risk today
Vendor inventoryManual, often incomplete
Due diligence evidenceEmails, no central record
Contract trackingCalendar reminders, ad hoc
Monitoring evidenceHard to produce on request
Examiner preparationDays of manual collation
Annual costStaff hours + risk exposure
✓
VendorAuditly
OCC-aligned TPRM for community banks
Vendor inventoryLive register, always current
Due diligence evidenceTimestamped, per vendor
Contract trackingExpiry alerts + clause analysis
Monitoring evidenceContinuous, auto-generated
Examiner preparationOne-click evidence pack
Annual cost$588/year ($49/mo)

OCC examiners don’t expect community banks to have a GRC platform costing $100k/year. They do expect a systematic, documented approach to third-party risk management that can be evidenced quickly on request. VendorAuditly provides exactly that, at a price that fits a community bank’s budget.


Common questions

OCC third-party risk management — FAQ

What does OCC Bulletin 2013-29 require?
OCC Bulletin 2013-29 requires OCC-supervised banks to maintain a risk management framework for all third-party relationships throughout their lifecycle: planning (risk assessment before engagement), due diligence (documented pre-contract assessment), contract negotiation (required provisions), ongoing monitoring (evidenced oversight), and termination (documented exit). Enhanced scrutiny applies to critical activities.
Who does OCC third-party risk management apply to?
National banks and federal savings associations supervised by the Office of the Comptroller of the Currency. The 2023 interagency guidance (jointly issued with the Federal Reserve and FDIC) extended consistent expectations to state-chartered banks as well. The framework is proportionate — community banks are expected to have programmes scaled to their size and complexity, not enterprise GRC platforms.
What is a critical activity under OCC third-party risk guidance?
Critical activities involve significant bank functions, sensitive customer data, or operations that are difficult to replace. Examples: core banking system providers, payment processors, cloud infrastructure, and cybersecurity monitoring services. Critical activity vendors require heightened due diligence, more frequent monitoring, sub-contractor oversight, and formal contingency planning.
What evidence do OCC examiners look for in third-party risk reviews?
Examiners look for: a complete third-party inventory with risk classifications, documented pre-contract due diligence with dates, contracts containing required provisions (audit rights, regulatory access, data security), evidence of ongoing monitoring activity with timestamps, and oversight documentation for critical activities. The key word is “evidenced” — documentation that monitoring actually happened, not just policies that say it should.
How does VendorAuditly help with OCC third-party risk compliance?
VendorAuditly automates the OCC third-party risk lifecycle: it maintains a live vendor register with risk classifications, records timestamped due diligence questionnaire responses, tracks contract expiry and required provisions, runs continuous monitoring with a dated evidence trail, and generates a one-click evidence pack for examiner reviews — all at $49/month with no IT team or compliance consultant required.
Does the 2023 interagency guidance change OCC third-party risk requirements?
The 2023 interagency guidance aligned and clarified expectations across US banking regulators rather than substantially changing requirements. Key clarifications: all banks are expected to have risk-based programmes proportionate to their size; board and senior management oversight is explicitly required; and third-party fintech relationships are highlighted as an area of examiner focus going forward.
OCC Bulletin 2013-29 — examiner-ready evidence

Stop managing OCC vendor risk in spreadsheets

Live vendor register, timestamped due diligence, contract tracking, and one-click evidence pack — at $49/month.

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