Hello everyone and thank you for joining me today for our Third Party Thursday podcast. I’m Kay Perry, Senior Operations Manager here at Venminder. Today’s topic is based on your overall third party risk management program and how to check the progress of the program now that you’re halfway through the year.
Let’s take it step by step with a few best practices:
- Dust off the policy, program and procedure documentation and do a quick read through. Based on what you’re seeing and any audit exam feedback, does the work product being produced and overall flow of communication seem to match what is outlined? It may not be time to make updates to this documentation just yet, but it’s always good to refresh your memory on the verbiage.
- Pull out your vendor list. Run through your vendor list and make sure no vendors, like recently invoiced or contracted vendors, have accidentally been forgotten to be added. If you've missed any, it's vital to get all of the appropriate documentation and perhaps also a good chance to remind the business unit about the importance of following the process.
- Check vendor performance. Are your vendors meeting expectations? Are you getting and reviewing the required reporting? Remember, OCC Bulletin 2013-29 specifically calls out ongoing monitoring as part of the overall lifecycle. It’s very important that you can ensure you’re not only vetting vendors at the beginning phases of the relationship but also as the relationship continues. Review their service levels and pull reports as needed to check and see that they are delivering what has been promised. Ongoing vendor monitoring is what we commonly consider the often “Forgotten Pillar of Third Party Risk Management.”
- Check your contracts and take a look at your contract management system. I’d encourage you to make sure no key contractual clauses or dates have been missed throughout the hustle and bustle of this year’s workload. Take a look at your system for managing contracts. Are all contracts in the system? If so, are all key dates such as expiration dates and contract renewal notice periods being tracked?
- Remember to use your reporting resources. This will give you great insight and visibility into the year’s progress and where things stand. A solid and comprehensive reporting package is an incredible tool to educate, involve and inform management.
- Make sure the board and senior management has been as involved as possible. Revisit big meetings or scenarios that occurred this year and make sure the level of involvement or exposure to the situation has been up to par and that is easily evidenced in minutes from the meetings.
I hope you found this podcast helpful. Continue to tune into this series as we’ll discuss next steps to document your findings and improve the process if needed. Again, I’m Kay Perry, Senior Operations Manager at Venminder. If you haven’t already done so, please subscribe to our Third Party Thursday series.