Venminder Blog

Hardly a week goes by that we don’t learn of some new major breach, incident or some emerging cybersecurity threat. Think Swift attacks, Equifax or Yahoo. It seems no one is immune from [...]

Have you heard - the CFPB could start hiding consumer complaints, Mortgage Bankers Association says cyber crimes are getting nastier and nastier (and they have examples to prove it!) and even the  [...]

I know it seems like third party risk management is getting more attention than it needs. I say that having been involved with various facets of vendor management for much of my 28 years in [...]

This week's third party risk related news stories cover a variety of topics - bank regulatory actions are at a historic low, Congress back in session and perhaps ready to look at regulatory [...]

Whether you know it or not, you need to be a news-hound in third party risk management. This helps you stay informed and educated. 

Check out the latest stories in the world of third party risk for the past week - an update on regulatory relief, the compliance costs that are hurting rather than helping consumers, whether or [...]

Like many others, you may find the introduction of spring to be a great time to do some spring cleaning. While you’re dusting off the shelves and clearing the clutter it may not hurt to [...]

Read below for the FFIEC's opinion on exam modernization, the CFPB teaming up with the FTC,  possible regulatory relief for community banks, fintech companies in Arizona, the FDIC announces [...]

A risk assessment should not include just the inherent risk or residual risk with the vendor. In order to complete a robust assessment, both inherent risk and residual risk levels should be [...]

Read about the latest Wells Fargo enforcement action, what a less aggressive CFPB could mean for Fintech companies, the major third party implications on illegal debt collection, what Regtech is [...]

From a best practices perspective, did you know there is a distinct difference between a critical vendor and high risk vendor? It’s common to see these two vendor types grouped as one, however [...]

While there is not as many shocking news stories this week, there are, however, some interesting bits of news on data breaches, threats to the banking system, perspective from the new OCC head and [...]

As part of our Venminder Thought Leadership series where we speak with the industry’s sought-after thought leaders for their perspective and advice on third parties, mitigating risk, best [...]

• Wells Fargo is in trouble again
• SEC hits [...]

A lot went on in the world of third party risk management this week - some of the top news stories include:

• Regulators are cracking down on Fintech and brokerage companies
• SEC weighs in on [...]

Unfair, Deceptive or Abusive Acts or Practices (UDAAP) is an area of intense focus by regulators at the moment. Since the creation of the Consumer Financial Protection Bureau (CFPB), there has [...]

This week in third party risk news, articles cover topics like:

• Updates with the CFPB
• Security and fraud cyber attacks cost the U.S. economy how much? The number is astounding!
• Efforts the U.S. [...]

One of my most exciting lessons in the world of compliance was that we could actually take credit for doing the job well or for investing in education.

Compliance and third party risk management [...]

This week in third party risk management news:

• Want to voice your opinion on CFPB regulation through enforcement action? Now you can - they're seeking input from the public.
• Legal analysis of the [...]

Vendor management and its requirements have grown significantly over the past several years. There is now increased attention to subservice providers (fourth parties) and expectations around [...]

What's new in third party risk management this week? Read below to find out the progression of the OCC's proposed Fintech charter, what Mulvaney is doing regarding the CFPB, a possible OCC and [...]

I was asked at a speaking engagement what I felt was the most difficult part of third party risk management. My answer, quite cumbrous, was “all of it”.

The week of Jan 29 saw some really amazing headlines. The CFPB seeks public input on its processes and enforcement actions, new debt collection rules with third party implications and now they [...]

I will admit I was surprised to learn that even the largest companies may have third party risk sitting on the corner of ONE person’s desk. Worse yet, it is often times just ONE FACET of a busy [...]

This week brings all sorts of BIG news from CFPB, OCC and the Federal Reserve affecting third party risk. The new director for the CFPB unleashes some significant changes in process and the OCC [...]

One of the things I pride myself on is being highly organized (is it a problem if my socks are arranged alphabetically by color?). In the ever-hectic world of a third party risk manager, you’re [...]

Read below for the most important news articles in third party risk for the week of January 15, 2018. There’s lots of articles this week on the challenges in financial institutions – whether it’s [...]

Regulatory guidance is clear – you must keep your senior management team and the board informed on developments in the third party risk management program, particularly on activities related to [...]

This week in the world of third party risk management, several resources take a stab at 2018 predictions and we again hear about the importance and increased role of of cybersecurity. The concept [...]

We all know the importance of getting regular checkups on our health. It’s a great way to proactively address any potential problems before they become a crisis. Well, third party risk management [...]

New year, new vendor management news. If this week’s news is any indication, we’re in for a wild and wacky year! 

We’ve got lots more CFPB news (the current head of NCUA may be named as the [...]

Exercise more, lose a few pounds, adopt a new hobby and spend more time with family and friends are all common New Years Resolutions.

Instead of losing weight for 2018, we've decided to focus on [...]

It's the last week of the year and the vendor management news hasn't stopped. This week's headlines reflect back on 2017 and outline priorities for 2018. Not surprisingly, enforcement actions, [...]

Writing a risk assessment document for the first time or the thousandth time can be a daunting task. People often struggle with how much there is to consider.

So, let’s narrow the focus and go [...]

Top stories in vendor management related news for the week of December 18, 2017 include:

• New York cracks down on data issues following Equifax
• CFPB is stopping its exams while they figure out how [...]

He’s making a list, he’s checking it twice, is your vendor naughty or nice? The regulators are comin’ to town… 

We've collected vendor management news articles from the past week starting with December 11, 2017. A few top ones are:

• 3 things to consider in vendor risk management
• An update on the battle over [...]

Vendor management and its requirements have grown significantly over the past several years. There is now increased attention to subservice providers (fourth parties) and expectations around [...]

This week in the world of vendor management was all about the changes in the regulators’ leadership and the ongoing power struggle at the CFPB, with a side order of data breach and proposed [...]

At the conclusion of any examination or audit, there are always some open items. No one truly enjoys having a detailed re-hashing of areas of concern, but it’s an important conversation to have.

[...]

This week’s vendor management news is dominated by the change in the leadership at the CFPB, UDAAP action and a new head at the OCC. Check out more of the important third party risk related news [...]

I’m often asked about termination clauses in contracts. Unfortunately, if you’re in the middle of an existing contract and decide you “want out”, your options may be limited, depending on how much [...]

Third party risk news for the fourth week of November brought us some interesting headlines - here's what to expect in this week's Staying On Top of Vendor Management News:

• If you haven't heard [...]

We’re thankful for our company, our customers and our ever-growing set of products and services. As we pause to spend Thanksgiving time with our families and friends, we thought it would be a good [...]

Some weeks there’s lots of news; some weeks there’s big news – this week, there’s simply lots and lots of big news.

Let’s look at some of the massive headlines:

• The CFPB director is stepping [...]

A common question we hear is “How do we know what the examiners will ask related to vendor risk management?” It’s one that does not lend itself to an exact and easy answer. However, there are many [...]

This week once again reminds us that keeping up with third party risk management news is a very important best practice. Here are some of the top stories:

• An exerpt from Chairman Hensarling's [...]

In light of Halloween, we've got some spooky third party risk management news to share with you this week.

• Back from the dead - first national bank charter approved since the financial crisis
• [...]

Vendor management doesn't always go smoothly and sometimes can get quite frightening. So, in the spirit of Halloween, I have 7 vendor management nightmares to share with you. Ensure you take the [...]

Fortunately, there hasn't been anything too crazy happening in the world of third party risk this past week. There are still some good articles to read though to keep you updated! Check them out [...]

"The first thing we do, let's kill all the lawyers" is a well known quote from Shakespeare’s Henry VI Part 2.  I was an English major, so I read a lot of Shakespeare and I don’t particularly agree [...]

Third party risk news for the week of October 16 that you need to know:

• Oversight on FinTech companies is tightening up
• Are you a smaller bank? You might be experiencing higher regulatory costs [...]

On September 28, 2017, the Office of the Comptroller of the Currency (OCC) released BankFiscal Year 2018 Bank Supervision Operating Plan, aka, NR 2017-113. Thanks for the acronym fun… but what [...]

Learn what's new in vendor risk management from the week of October 9 - there have been some real eye openers. We've put together a list of resources that cover a variety of important topics, [...]

Learn what's new in vendor risk management from the week of October 2. We've put together a list of resources to check out. 

It’s been an interesting week – topics include:

• OCC dangles idea of [...]

Your third parties should be ranked as Critical or Non-Critical for business disruption and ranked High, Medium or Low on all regulatory items.

This week in third party risk news, we are reminded of the importance of proper due diligence, reputation risk, examination preparedness and more vendor management best practices. Read the [...]

A fundamental question people often wrestle with is, “what constitutes appropriate vendor due diligence?” Or, “what are vendor due diligence reviews”?

Headlines in third party risk from this past week, the week of September 18, covered a variety of mishaps from which we can all learn. Read the articles below for how you can avoid issues with [...]

As you may have seen this week in the news, the first of the Apple Pay contracts are up for renewal; if you haven’t seen it, here’s a handy link to the article. 

Keeping up with the latest news in third party risk is important for your vendor management program. This past week - week of September 11 - has been especially eventful. Make sure to check out [...]

If you’ve done much due diligence work, you’ve certainly noticed that many vendors incorporate here in Delaware (well, technically, I live in southeastern Pennsylvania but have worked for most of [...]

Keep up with the latest news in third party risk. We've put together a list of resources for the week of September 4 to help keep you updated.  

I’ve seen on Facebook and Twitter those amusing things where you list what you wish you could tell yourself 20 years ago, i.e., sharing the benefit of experience with a less experienced YOU. 

[...]

If you’re like me, you receive dozens of emails – perhaps hundreds of tweets – from various news feeds. It’s easy to lose track of them all but it's important to at least glance through them. 

Here's a list of important vendor risk management articles from this week - week of August 21, 2017.

There is an old saying that goes, “an ounce of prevention is worth a pound of cure”.  Meaning the cheapest way to fix a problem is often to simply prevent it from occurring. Perhaps there is no [...]

What's new in vendor risk management for the week of August 14, 2017? We've put together a list of resources to check out.

The optimist sees the glass as half full; the pessimist sees the glass as half empty; the engineer sees a waste of too much glass; the compliance officer sees it as potential shattering and [...]

You're aware of the importance of staying up to date with industry news. Learn what's new in vendor risk management for the week of August 7, 2017. We've put together a list of resources to check [...]

When I’m not at work, you’ll most likely find me on my bicycle. Some might argue that I am cyclelogically obsessed with bicycling (see what I did there?). One sure thing every cyclist knows is [...]

You know how important it is to stay updated with regulatory news. Learn what's new in vendor risk management from the week of July 24. We've put together a list of resources to check out. 

You need to know the business impact risk of your vendors. Once you know that, you can figure out how they play into your financial institution’s business continuity plan. A way to start is to [...]

This week, we’re at the NAFCU Risk Conference in beautiful Denver, Colorado. For me, attending conferences, whether as a presenter or as an interested participant, is always exciting.

As we've mentioned before, it's important to stay updated with regulatory news. Learn what's new in vendor risk management this past week. We've put together a list of resources to check out. 

[...]

If you had an examination starting tomorrow, would you be ready? If one of your critical third parties announced it was ceasing business, would you be prepared? If there’s a big data breach at one [...]

The creation and issuance of vendor management regulatory guidance takes quite a while – the process from start to finish can take months or even years. Meanwhile, the evolution of mobile [...]

Vendor management should have its own department or group inside your financial institution. A best practice, perhaps even a fundamental expectation, is that third party risk management should be [...]

As we've mentioned before, it's important to stay updated with regulatory news. Learn what's new in vendor risk management this past week. We've put together a list of resources to check out. 

As a professional in third party risk management, you probably hear the term service level agreement or SLA for short. Make sure you understand what they are. To help, we'll go through a few basic [...]

As we’ve mentioned before, one of the challenging issues in third party risk management is staying up-to-date on news and changes occurring in the financial services regulatory world. It’s [...]

The examiner is coming, the examiner is coming!

DON'T PANIC! Seriously, there’s no need if you’re running a well-managed program. Let’s go through some of the key things you’ll want to do to plan [...]

Vendor ongoing monitoring is required by all of the major regulators as a fundamental practice in third party risk management. So, why is it often overlooked? What happens if you fail to monitor [...]

Extra extra! Read all about it! Last week, the Office of the Comptroller of the Currency issued Bulletin 2017-21 –Frequently Asked Questions to Supplement OCC Bulletin 2013-29.

We thought it might [...]

In the past, we covered that the board needs to be involved in your vendor management program and how to figure out if they're involved enough. We also covered important points on what vendor [...]

Today, companies merge suddenly and frequently for a variety of reasons - some of those reasons can be a really good thing, but some can introduce a variety of risks that can cause performance to [...]

In the story, “The Purloined Letter” by Edgar Allan Poe, one of the key themes was thatthe most obvious things are often hidden in plain sight – we just manage not to see them. The same is true of

As you may already know, I’m a cyclist. So, typically, I log a few miles every morning before work, amuse the neighbors by posting pictures of my ride on Facebook and generally enjoy rolling along [...]

If you have listened to some of our webinars, you’ve heard me recommend reviewing legal analysis of the voluminous or complex new vendor management regulatory guidance. Rather than digging through [...]

It can be tempting to cut corners when handling third party risk management at your institution. 

When I was a few years younger, I used to love to race in criterium style races… for those of you [...]

Enforcement action – for anyone involved in risk management, that term can give you an upset stomach. Why? An enforcement action typically means large problems and potentially hefty fines. They [...]

There's a question I get asked often - "Why must I risk rate EVERY one of my vendors?" Many times at conferences and in follow up to webinars, this is a popular question, because I think it drives [...]

One of the real regulatory hot buttons over the past few years is around UDAAP – Unfair, Deceptive, or Abusive Acts, or Practices. There have been numerous UDAAP violations with some pretty [...]

The OCC came out with new guidance on January 24, 2017 - they published the supplemental examination guide for third party risk management, titled OCC Bulletin 2017-7. So, if you’re at a credit [...]

A topic we hear a lot at industry conferences and webinars is the maturity of your vendor management program. What exactly does this mean? Let's go through that now...

If you don’t read anything else this week on vendor management, read this! Recent studies by Protiviti and Crowe Horwath show that vendor risk management maturity has improved significantly, but [...]

On March 13, 2017, as the East Coast of the US was awaiting the latest snowpocalypse or snowmageddon, really big news broke related to vendor management – D+H was acquired and will be merged with [...]

How are financial institutions handling vendor management for 2017? After surveying over one hundred people, we have good and bad news to share, data to back it up and how to make the bad news [...]

There are times when even the best of relationships fall apart. But, there's also usually plenty of early warning signs. So, let's look at a few of them related to your vendors – these are just a [...]

On Tuesday, January 24, 2017, the Office of the Comptroller of the Currency issued new regulation - Bulletin 2017-7. It's supplemental guidance on the approach examiners must take when reviewing [...]

How often do you check your oil in your car? The air pressure in your tires? Do you take your car in for routine maintenance? Or do you ignore everything until a warning light appears on the [...]

You should prepare for an exam before you're officially given notice of it. There are items to have ready ideally 3 or 4 months before any potential exam window.

With the new year, you may reflect upon how things are going within your bank or credit union's third party risk management program. Make sure your team is on the same page.

I was recently at a [...]

A few weeks ago we discussed the importance of senior management and board involvement regarding vendor management. How do you know if you're following the OCC Bulletin 29-2013 guidance and OCC [...]

I anticipate that there will be quite a few changes looming in the new year - 2017. Some examples include change of Dodd-Frank, increased pro-bank feel, change of examination cycle and [...]

2016 – the year of third party risk and cybersecurity. As 2016 winds down, we should look back and think about what we’ve seen this year. There have been many extraordinary events in the world of [...]

I was recently asked what a MRA is and what it really means. Well, if you’re a compliance officer at a financial institution, that acronym is enough to send a shiver down your spine.

Just as the leaves changing or the geese migrating herald the change of seasons, things change for companies as well. And, if those companies are a critical third party of yours, you need to be [...]

If you’re a senior manager or a member of a board of a financial institution, you must be directly involved in many things, including vendor management. If there was any doubt about that, the OCC [...]

While I may not be entirely thankful for the heightened state of today’s regulatory environment, I am thankful that we live in a time of innovation and, therefore, have helpful tools to assist in [...]

Reporting to senior management and/or the board is not just a good practice; it’s actually a requirement of regulatory guidance. So, what should you prepare in terms of a report?

The simple answer is “yes”. If they fall within the scope of your third party risk management program – and remember, your scope should be well documented on who is included and, just as [...]

Here's a classic dilemma – what happens when a vendor simply won’t give you the documents you need to complete due diligence? Do you stand up and walk out on them? Usually not... but you do need [...]

Vendor management doesn't always go smoothly, and sometimes can get quite frightening. In the spirit of Halloween, check out these 17 vendor management horror stories followed by ways to stop or [...]

We have exciting news! Have you heard? Yesterday, we launched our new educational video series - Third Party Thursdays. Every Thursday, we will post a new video that will focus on a different area [...]

One of the most important and challenging parts of working in risk management is staying out of the news – that’s always a good goal, not to be in the news in a negative way. But equally [...]

You’re getting ready to do business with a huge industry leader. Why, there’s no need to try to do the usual due diligence, is there? They have to be safe.

I mean, they’re never going to give us [...]

You’ve probably updated your organization chart for your bank or credit union's compliance and third party risk management teams. You’ve likely had to explain it to Human Resources or go to senior [...]

Anyone who knows me knows I have a few obsessions – I’m cyclelogically obsessed with my bicycle and I am an absolute NASA-nut (thanks to Twitter and NASA Social for taking me to some really great [...]

On Aug 22, 2016, the FDIC released the Summer edition of its Supervisory Insights Journal. Okay, officially, it was FDIC Financial Institution Letter 57-2016, but that’s too much of a mouthful, so [...]

Unfortunately, there’s no magical solution to getting your staff up to speed and keeping them there. There’s no handbook or vendor management Bible, and even the best guidance only gets somewhat [...]

We were recently asked if there is a certain size threshold at which an institution should or should not consider outsourcing. The discussion led to a lot of thoughts – but when it came down to [...]

No serious cyclist would ever dream of riding their bicycle without wearing a helmet. Personally, having been hit by a car twice while cycling, I probably should wear a helmet every time I talk [...]

I was very fortunate when I worked in a bank; I generally always got the support and investment that I needed to run a third party risk management program.

Talking to my colleagues throughout the [...]

Dealing with third parties is a lot to have on your plate, however examiners think you can still handle more. They will ask you about your fourth parties too!

What in the world is a fourth party [...]

Why do I want to go into a relationship thinking about the exit?

It does seem counter-intuitive, I suppose. You're all excited about signing up this great new provider who is going to help solve [...]

You’re excited to be working with a terrific new vendor. Let's go through the process.

You’ve done your due diligence, written a thorough risk assessment, gotten it approved by your risk committee [...]

Why do we do due diligence?

There is always the natural tension between wanting to get to market with a good idea or new service provider and the need to do your homework and make sure the [...]

Okay, I’ll admit it – there are always certain companies that I admire and are my favorites to do business with. 

I won’t name names, but as you read this, hopefully you can identify ones of your [...]

Of all of the areas of third party risk management, perhaps the most difficult is handling contracts effectively. Whether it’s negotiating, tracking or simply finding all of them, contracts can be [...]

Anywhere your company is spending money for a product or service, well, that’s a vendor of some sort. As part of your vendor management, you need to start by knowing who exactly your vendors are. 

Not all due diligence should be rated equal

Due diligence should always be risk-based and tailored to the appropriate risks represented by the third party relationship. Lots of the items collected [...]

Since Prince’s passing, the lyrics to his song “1999” kept coming to mind, which then triggered me to think about how vendor management has changed from then to now.

You may have seen the news, reported in Krebs On Security and elsewhere, that payroll processing giant, ADP, was compromised by identity thieves, resulting in the loss of tax and salary data. 

A little over ten years ago, I was leaving MBNA America following an acquisition by Bank of America. 

I really hadn’t searched for a job in nearly 20 years, so I wasn’t quite sure where to start.

[...]

Using Excel for your vendor management can make the data cumbersome for you to manage and difficult for your examiner to read. So why are you still using those spreadsheets?

It's time to move on! [...]

Vendor management has been around for years. Having a firm grasp on the companies with whom you are doing business is not new, but the regulatory expectations continue to evolve and grow.

Whether [...]