Fintech · Industry brief

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On September 11, 2026, the Federal Reserve, FDIC, NCUA and OCC proposed revised interagency guidance on third-party risk management that would replace their 2023 guidance. The new Proposed All-Bank Guidance emphasizes a streamlined, principles-based approach focused on material financial risks rather than process-driven compliance, and explicitly aims to reduce regulatory impediments to fintech partnerships with banking organizations. The agencies identified that the 2023 guidance was interpreted too broadly and "unduly impede[d] fintechs from entering partnerships with banking organizations." The revised guidance establishes four risk management components: identifying and assessing risks, overseeing risks proportionally, making informed decisions about residual risk acceptance, and establishing appropriate governance, with tailoring based on bank size, complexity and risk profile. Comments are due November 16, 2026. (Source: Federal Register, 91 Fed. Reg. 58,536, Sept. 15, 2026) The Federal Reserve separately proposed a non-binding Community Bank Guide for institutions under $30 billion in assets, and the Federal Reserve, FDIC and OCC issued a joint statement on community banks' relationships with core service providers, committing to risk-based supervision and potentially pursuing direct enforcement actions against core providers that unreasonably limit due diligence and contract negotiations. (Source: Federal Register, 91 Fed. Reg. 58,438–58,440, Sept. 15, 2026)

On September 16, the New York Attorney General's Office settled with two Westchester County dealerships over deceptive fee practices, requiring $1 million in immediate consumer restitution, millions more in claims-based payments, and $700,000 in penalties. The OAG found that a 2% "Sales Commission" charge applied to 96–97% of transactions was not adequately disclosed as optional, despite being labeled "not required by law"—language the regulator found ambiguous and misleading. The dealerships also bundled aftermarket protection products priced up to $2,495 with illusory benefits and poor disclosure; a "collision credit" was only reimbursable if the consumer leased another vehicle from the same dealership within 60 days. The settlement prohibits both dealerships from charging any sales commission fee or offering similar bundled add-on products going forward, and mandates standalone elected-options forms requiring affirmative written consent, dealer worksheets showing negotiated pricing before finance office entry, and mandatory annual compliance training. The OAG rejected two rounds of incremental disclosure revisions (May 2022 and September 2024) as insufficient to cure the underlying labeling problem, signaling to industry participants that regulators treat high acceptance rates on purportedly optional fees and mislabeled charges as evidence of de facto mandatory pricing regardless of stated optionality.