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If you haven't been watching carefully, you may not know that the banks are going to get whole lot of guidance about using independent consultants just in time for the holiday season. While it looked like the New York State Department of Financial Services might be first to issue such standards, the Office of the Comptroller of the Currency (OCC) beat them to the punch Tuesday. The OCC guidance "focuses on enforcement actions that require the employment of an independent contractor to address significant violations of the law, fraud or harm to consumers." In addition to reminding banks that they...