Regulatory Exams and Audits for Vendor Management: Preparing for 2022

There’s no denying that most organizations are taking large strides to return to a normal pace of business in the aftermath of 2020. We’re starting to see a big uptick with organizations working to brush up their policies, programs and processes with either the anticipation or onset of resuming exams. 

Whether you’re new to the exam process or brushing up on the latest and greatest, here are a few things to think about for 2021 as we head into 2022 regulatory exams and audits:

How has the last year reshaped the third-party risk exam process?

• A change in work environment: The pandemic has increased the working from home landscape tremendously. This means that the landscape for malicious cyber activity has expanded greatly. Locking down your security practices internally and across the pertinent vendor inventory is of extreme importance and should be a focal point for any exam where information security is in scope.
• Shift in social and political appetites: The next few years are likely to bring more attention to ethics and social responsibility, not just conceptually, but practically and tangibly. For now, there are no tangible mandates associated with the increased attention towards corporate social responsibility (CSR) and environmental, social and governance (ESG), but we anticipate a growing momentum in this arena.

With all that said, we still shouldn’t lose sight of the basics. Most organizations have undergone shifts to support mandated global shutdowns. Maybe the shift was subtle, but in most cases, resources were low, employees were hard to find, organizational changes were made, and with that, processes were likely adjusted. What that also means is that perhaps policies and procedures that are audited by examiners may not actually reflect our new normal. At least, not in such a way that would pass regulatory muster.

What do we need to know about CSR and ESG?

Generally speaking, CSR pertains to how an organization responds to ethical concerns, and how that might impact the opinions of stakeholders, investors, customers, employees and the general public. ESG metrics are used to measure how well an organization might be meeting those ethical goals.

CSR and ESG conversations are making their way to various agendas across industries internationally. While so far there aren’t any strict tangible metrics or obligations needing immediate attention, this is an optimal time to start the conversation within your organization about the ethical standards that are in place, how you can start to track, measure and report on your goals, and with that, how you can begin carrying those expectations and standards into your vendor vetting process.

There’s a good chance that these considerations will remain ‘soft law’, however, getting ahead of any potential forthcoming expectations for reporting will give you the strategic advantage of time to plan and execute any changes efficiently and practically.

General Preparedness and Everyday Best Practices

Of course, there are always the tried-and-true methods for preparing for any exam which should be considered now more than ever. Consider the following practices:

• Understand regulatory requirements: Step one in meeting expectations is understanding what they are. Beyond reading the guidance, it may even be helpful to reach out to your examiners to level set prior to your exam. Try staying ahead of scrutiny by understanding where your process may fall short and have a plan in place for improvement.
• Authenticate governing documents: Be sure your policies and/or procedures not only confirm adherence to those regulatory requirements, but that they also accurately reflect your day-to-day operations. Your process deliverables and controls should be reflected in your governing documents, as this is usually how an auditor or examiner will test your process and the adequacy of your control environment.

As you can see, our recommendations for the next year are a mix of tactical, strategic and a little old hat. We hope you find this helpful for all your pending successful exams.

Interesting in learning more about 2021 third-party risk management trends and best practices that you should take into 2022? Check out the whitepaper.