# Which deadline should bank buyers keep on the calendar?

**Watchlist—not a new announcement:** Comments on the proposed interagency third-party risk management guidance are due **16 November 2026**. The proposal favours tailoring oversight to the risks of individual relationships rather than treating every relationship as inherently high risk. The OCC describes the proposed guidance as non-prescriptive and non-enforceable; do not present it as a final regulation or an immediate software mandate. ([govinfo.gov](https://www.govinfo.gov/content/pkg/FR-2026-09-15/html/2026-18859.htm?utm_source=openai))

**Buyer action:** Demonstrate two different vendor risk management paths: a lower-risk supplier and a material outsourced service. Test whether the buyer can explain—and later change—the assessment depth, approval route and monitoring frequency.