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Examination Preparation

Challenging a Vendor Management Examiner: What You Need to Know

Jun 24, 2020 by Branan Cooper

We all know exams are stressful, and sometimes they can be downright awkward. But most of us have had this thought at least once, “are there ever instances where it’s acceptable to challenge an examiner?” The answer to that is yes, you respectfully may. Of course, if there are misunderstandings or misstated conclusions, then they should certainly be addressed. I’ve had many occasions where I felt the need to in the utmost professional way say we need to discuss this. This is my way of saying, “I’m challenging this.

Typically, when you feel the need to challenge an examiner, it happens for one of two reasons:

  1. You feel an examiner’s assessment is wrong. If that’s the case, it’s extremely important to dot those I’s and cross those T’s when it comes to third-party due diligence and having all your documentation in order should you need to use it support the facts and/or your point of view.

  1. The examiner’s assessment is accurate, but not truly a problem. Although accurate, you may not agree it’s truly a problem or you take issue with the reporting method. 


6 Tips to Approach and Challenge a Vendor Management Examiner

What do you do when you find yourself in an examination scenario where something isn’t sitting well?

Follow these 6 tips:

  1. Keep it professional. Follow the golden rule! Even if disagreements or conflicting viewpoints rear their heads (and at one point or another, they will) discussions will be much more productive as long as you approach the situation with professionalism and respect, just like you would with anyone you work with.

  2. Maintain transparency. Ensuring you keep the vendor management examination process open and transparent from the start helps all parties involved better understand each other’s opinions and participate in the process.

  3. Lean on documentation to educate. Examiners, just like any other colleague (and me, certainly, on many occasions), just may need some re-education or clarification to better understand a situation or the facts.

  4. Avoid finger-wagging. If you’re outright admonishing or criticizing an examiner, it’s not going to work out well. That’s generally true of any business situation. However, if handled appropriately, it can lead to a very meaningful resolution.

  5. Agree to disagree. I have many examiner friends with whom I’ve shared many differences of opinion, and despite best efforts, sometimes still arrived at opposite conclusions. But more often than not, reasonable minds prevail, and I enjoy my working relationship with various examining authorities.

  6. Focus on an action plan. Instead of getting locked into a battle of warring opinions, a more successful resolution strategy will focus on the significance of the finding(s) and a recommended action plan.

Examinations and examiners, when "handled" properly, can help prevent much larger problems like future enforcement actions or business constraints. Even informal commentary in a challenging situation may lead to a better way to inform an examiner in the future. Therefore, hopefully it’s a little less awkward for all parties involved the next go-around. It’s all a learning experience, so take it in stride!

Just like all of us, examiners are just trying to do their job. Educate them on your business and the nuances of your services and products. When necessary, discuss concerns on potential issues, and of course, be professional. There’s no science to it. I go back to the mantra of be respectful and be kind. With this approach, you’ll generally get the same in return.

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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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