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Due Diligence

Back to Basics: 6 Core Elements for Your Vendor Management Program

Dec 3, 2019 by Branan Cooper

Vendor management, or third party risk management as it’s more commonly referred to, has been around for years. Having a firm grasp on the vendors with whom you are doing business isn’t new, but the regulatory expectations continue to evolve and grow at a rapid pace.

Whether you’re dealing with the very basic supplier or the most cutting-edge high-tech organization, there are certain things you should discern about every vendor. 

6 Core Elements for Vendor Management

The basics of vendor management are well-explained in regulatory guidance (e.g., FDIC FIL 44-2008FIL 3-2012OCC Bulletin 29-2013, OCC Bulletin 7-2017), but to summarize some of the guiding principles, let’s review… a well-managed and functioning program should include at least these 6 core elements:

1. Due Diligence Standards 

Set due diligence standards around vendor selection. Know the organization with whom you’re doing business. Determine their good standing and licensing to conduct business. Learn about their reputation and gather documents to show they are a well-managed and compliant operation.

2. Assess the risk 

As you gather the various due diligence documents, start looking for gaps or areas that may cause concern. Use a rating system to be objective and consistent. Where you identify risks, determine what you can do to address and minimize exposure.

3. Ongoing Monitoring 

How will you manage this vendor going forward? Are there performance metrics that will require regular reporting? Is there some sort of quality of service you need to measure? 

4. Contract Standardization 

Be sure that the vendor has certain obligations, such as notifying you of a data breach or changes in ownership or leadership. Make sure each parties’ roles and responsibilities to one another are clearly defined.

5. Termination and Exit Strategies

Unfortunately, every vendor partnership comes to an end. Prepare for this by determining early on in the relationship how termination will be handled. Address items like the notification process, how data will be destroyed or returned and if you’ll bring the function back in-house or outsource to a different third party.

6. Board Involvement 

Senior management and the board of directors must be kept informed of the status of your vendor management program. Inform and seek guidance and approval when needed.

You may be reading these five core elements and thinking they’re obvious, but surprisingly they’re often forgotten. Put a strong focus on each one and your program will be headed in the right direction. 

Make sure you meet all the necessary regulatory requirements for third party risk. Download the checklist. 

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Branan Cooper

Written by Branan Cooper

Branan Cooper is the Chief Risk Officer at Venminder. Branan has nearly 30 years of experience in the financial services industry with a focus on the management of operational and regulatory processes and controls—most notably in the area of third party risk and operational compliance. Branan leads the Venminder delivery team as the third party risk management subject matter expert in residence. Branan also serves as an industry thought leader. He's a member of InfraGard and the Professional Risk Management Industry Association (PRMIA). And, he was selected in 2018 as an advisor to the Center for Financial Professionals (CEFPro) and board member for the Global Sourcing Resource Network (GSRN).

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