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. In the past we talked about performing mid-year third party risk management progress checks and what to look for (listen to last week's podcast here - How to Do a Mid-Year Third Party Risk Management Progress Check). In today’s discussion, we are going to discuss next steps to document findings and improve upon the process if necessary.
Let’s take it step by step with a few best practices that we encourage:
- Make the necessary changes to your policy, program and program. If you’ve reviewed your policy, program and procedure documentation and have found that the work product and communication between the lines of defense isn’t matching what is outlined, then it’s time to make some changes - hopefully you've already done so, but, if not, it's definitely time to do so.
Start by clarifying any misunderstandings or disconnects between work product and the third party risk management policy or program documentation. Next, go ahead and reach out to the various lines of defense and internal teams to get any issues resolved. It’s much better to be proactive and begin addressing them now, instead of an examiner finding them.
- Perform a side by side review and add any missing vendors to the third party risk team’s vendor list. Did you review your vendor list and you’re not absolutely sure each vendor is captured? Maybe you already noticed two or three fairly new relationships that are missing from the list. Go ahead and request an updated list from Accounts Payable. Perform a side by side review and add any missing vendors to the third party risk team’s vendor list. Equally important, be absolutely certain to go back out to the lines of business to ensure they understand the process of onboarding new vendors so that you don't continue to have this problem. Ensure the proper monitoring is being performed, especially on vendors who had been left off for whatever the reason may be.
- Document any findings regarding vendor performance. You’ve reviewed each vendor’s contracted service levels, pulled reports, spoken with colleagues to hear more about their day-to-day interactions with the vendor and have found that some aren’t meeting expectations. Document the methods of reaching out, who’s responsible for doing so, as well as the date and next steps you are taking to address service level or performance issues with the vendor.
- Document that a vendor contract review was performed. Once you’ve reviewed your contract management system to verify all the key dates such as contract renewal notice periods and expiration dates are being tracked, go ahead and document that a review was performed. If any dates or contracts were missing from the system, make updates accordingly.
- Do a thorough evaluation to find any potential gaps in your third party risk management policy and/or program. Once you’ve pulled together your third party risk management policy and program and you're confident that you have accurate reports, do a thorough evaluation to find any potential gaps in the process. If gaps are found, document and re-mediate as soon as possible.
- Update the board and senior management on any findings. Schedule a meeting if necessary and discuss next steps and expectations for the organization to tackle any areas that need improvement.
I hope you found this podcast helpful. 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.