It’s the billion-dollar question – what is on a regulator’s mind when they walk through the door of a firm? What kinds of things are they looking for – and is the firm prepared?
The focus on third party risk management by regulators has increased significantly over the past few years. The regulators themselves are providing some clear and coherent guidance on their expectations, such as: OCC Bulletin 2013-29, “Third-Party Relationships: Risk Management Guidance; FFIEC Appendix J: Strengthening the Resilience of Outsourced Technology Services. And, if you’re looking for a ‘crib-sheet’ of what the examiners are likely to be looking at, there’s also OCC Bulletin 2017-7: The OCC's Supplemental Examinations Procedures for Third Party Relationships.
In February 2018, Aravo brought together a panel of experts, two of whom were former US regulators, to talk about how supervisors are thinking about third party risk management. You can listen to the broadcast here – but we’ve also distilled it down into five key take-aways.