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HfS comments on the recently published Federal Reserve Board and OCC guidance on the use of outsourcing providers, and specifically on the implications for all governance groups, independent of industry. The key focus in the updated guidance is the need to adopt a “life cycle” risk management model, establish specific procedures and actions for each risk tier and stage in the life cycle, and ensure Board approval and ongoing visibility. HfS provides specific compliance recommendations for enterprise governance groups in preparation for federal regulators.
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