On April 24, 2023, the Office of the Superintendent of Financial Institutions (OSFI) published its final updated Guideline B-10: Third-Party Risk Management Guideline (the “Guideline”), which outlines OSFI’s expectation that Federally Regulated Financial Institutions (FRFIs) take a risk-based approach to manage third-party arrangements. OSFI undertook a 5-month public consultation process following the release of a draft Guideline B-10 last April (“Draft Guideline”), based on which it updated the Draft Guideline with further clarifications regarding the application of and requirements under each expected outcome of the Draft Guideline. In particular, OSFI emphasizes that FRFIs should apply the Guideline in a proportionate manner based on the level of risk and criticality of each third-party arrangement. The Guideline will be effective on May 1, 2024. You can find our bulletin on the Draft Guideline here.
Proportional Approach in the Application of the Guideline
In response to concerns surrounding the Draft Guideline’s broad scope, the final Guideline provides that FRFIs should determine the “intensity” with which to apply its expectations…
