FRM Part II · FRM Exam Part II · Case Study: Third-party Risk Management
A bank is onboarding a cloud analytics vendor that will process confidential customer data and whose failure would halt daily risk reporting. Before signing, which action best reflects sound third-party risk assessment practice?
The best practice is to tier the vendor by criticality and data sensitivity and apply due diligence proportionate to that tier. A vendor supporting critical reporting and holding confidential data needs enhanced review before signing, not uniform light-touch checks or delayed diligence.
- ARely on the vendor's marketing materials and its low price as evidence of adequate controls
- BClassify the vendor by criticality and data sensitivity, then perform due diligence proportionate to that tierCorrect
- CApply identical light-touch due diligence to all vendors to keep onboarding consistent
- DDefer due diligence until after the first year of service, when performance data is available
Explanation
Sound practice is risk-based: vendors are tiered by criticality and data sensitivity, and the depth of due diligence follows the tier. This vendor supports a critical process and handles confidential data, so it needs enhanced review. Uniform light-touch review under-assesses critical vendors, and deferring diligence until after service starts exposes the bank before controls are verified.
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