Who Is Responsible for Vendor Risk Management?

Vendor risk management is a complex system of various processes that must be accomplished by many different roles within an organization. It may seem like only a few individuals are overseeing your vendors, but there are probably many more that are involved in your overall program. Let’s take a look at the roles and responsibilities that play a part in vendor risk management.

Who Is Involved in Vendor Management?

Before we discuss the different roles, it’s helpful to understand a commonly used risk management principle called the “Three Lines of Defense.” It includes the following:

• First Line: This is where the vendor risk is owned and managed. Roles in this position interact with the customers and vendors at a transaction level and therefore are the first to know if there are any problems. A vendor owner would be a typical first line role.
• Second Line: Overseeing the vendor risk management program and ensuring the completion of vendor risk management tasks. Their duties include assigning vendor risk management activities to the first line and ensuring responsible parties respond on time. The second line is also responsible for ensuring that the first line’s management of their third parties meets applicable standards. A third-party risk manager or vendor risk manager role would be in this position.
• Third Line: The roles and duties of lines one and two are supervised by the third line of defense. This line will also perform internal assessments for the purpose of corporate policy and program compliance. The internal audit department will be in this third line and report to either compliance or enterprise risk.

And, here are additional roles and responsibilities:

Dedicated Vendor Risk Management Team – Whether your vendor risk management program is comprised of a single individual or an established group of several people, the general duties will be the same. This team is responsible for the ownership and maintenance of the vendor management framework and policy, as well as reporting to senior management or board of directors. It will also prepare and respond to regulator exams or audits and conduct due diligence risk reviews with the help of subject matter experts.

Regulators –These are the actual governing entities, state or federal agencies which closely examine an organization’s process to ensure that specific rules and regulations are being met.

Examiners –These are the people who evaluate your vendor risk management program from a regulatory standpoint. Examiners will evaluate if your organization operates within the regulatory guidelines. From a third-party risk standpoint, an examiner will review all components of your framework and program to ensure you operate in a safe and sound manner.

Senior Management – Their involvement is a must. Even if the senior management team doesn’t have direct involvement in overseeing vendors, they should still oversee tasks like reporting to the risk committee.

Executive Leadership and/or Board of Directors – Regulatory guidance requires that these roles be involved in vendor management, especially with critical and high-risk vendors. Your organization’s board/executive leadership are responsible for approving the vendor management policies and essentially set the “tone-from-the-top.”

Internal or External Auditors – This team will help identify any gaps or concerns in your vendor management program that would otherwise be discovered by an examiner. Auditors can also share best practices and advise, while sharing suggestions on areas that need change.

Vendor Owner – The individual who owns the day-to-day relationship with the vendor and is responsible for reaching out to the vendor with questions, confirming the vendor submits necessary documentation, completing risk assessments and ensuring that any issues discovered in due diligence are mitigated.

Subject Matter Experts (SMEs) – Internal and/or external SME’s will provide a formal opinion on the sufficiency of controls and the severity of any gaps or issues within your vendor management program. These experts have obtained certifications that qualify them to provide this trustworthy feedback. For example, a certified public accountant (CPA) would be qualified to review a financial statement. SME’s can also perform risk reviews and assessments in areas like legal and compliance, information security or financials.

Third Parties –A company or entity with whom the organization has a direct written agreement to provide an outsourced product or service on behalf of the organization.

Fourth Parties –A company or entity with whom a third-party vendor has a direct written agreement to provide an outsourced product or service on behalf of the third-party vendor’s organization.

Who Is Responsible for Vendor Management?

Ultimately, Senior Management and the Board of Directors are accountable for vendor risk management. Each person who deals with a vendor plays a significant part in making the wheels turn. Keep in mind, if you don’t feel you can pinpoint in your organization the specific groups we’ve discussed, then you should take steps to ensure you do have them as they’re all playing an integral part in vendor risk management. Find the gaps now and fill them for next year.
Managing vendors isn’t a sole responsibility, but instead a joint effort. Teamwork makes the dream work.

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