Vendor risk assessment · financial services

How to run a vendor risk assessment your examiners can follow.

A vendor risk assessment shows which third parties matter most, what you checked, and what your firm decided. For RIAs, broker-dealers and funds, the record behind that decision matters as much as the decision itself.

What to assess

Six factors that shape vendor risk

Access to customer information

Does the vendor access, store or process nonpublic personal or sensitive customer information? This drives Regulation S-P scope.

Critical business function

Would an outage disrupt trading, client service, custody, reporting or recordkeeping?

Systems and data access

What networks, applications and data sets can the vendor reach, and with what level of privilege?

Use of AI and subcontractors

Does the vendor rely on AI tools or fourth parties that handle your firm's data?

Security evidence

SOC reports, policies, penetration-test summaries and insurance — current, complete and reviewed.

Contract protections

Incident notice, safeguards, audit rights, data return and termination terms.

The process

Six steps from inventory to documented decision

  1. 1

    Build the inventory

    List every vendor with its services, owner, contacts and the data and systems it touches.

  2. 2

    Assign a risk tier

    Your firm applies its own criteria to rate each vendor; the tier sets review depth and frequency.

  3. 3

    Run due diligence

    Send a questionnaire, collect evidence, and record dated review notes and findings.

  4. 4

    Review the contract

    Check key clauses against your requirements and record what is present, missing or in negotiation.

  5. 5

    Decide and document

    Your authorized reviewer records the outcome, accepted risks and any remediation with owners and due dates.

  6. 6

    Monitor and repeat

    Track expiring documents, incidents and the next review date so the assessment stays current.

ThirdNexa does the reading, chasing and paperwork: questionnaires, evidence collection, cited contract review, reminders and an activity history. Your firm sets the criteria, assigns the tier and records every decision — the software never labels a vendor approved.

Put the workflow to work

Run this workflow in ThirdNexa — your firm records every decision.

Import your vendor list or start from contracts, send questionnaires, collect cited evidence, track review dates and export the record for your examiner. Start free for 30 days — no credit card.

Common questions

Vendor risk assessment FAQ

How often should an RIA reassess a vendor?
Often enough to match the vendor's risk. Higher-risk vendors — those touching client nonpublic information or critical functions — are commonly reviewed annually; lower-risk vendors can follow a longer cycle. Your firm sets the frequency, and ThirdNexa tracks the next review date and reminds you before it lapses.
Which vendors belong in the assessment inventory?
Any third party that supports your business: custodians, portfolio management and reporting platforms, IT and cloud providers, outsourced compliance or trading support, marketing tools, and even office services with access to sensitive information. Start from your contracts and accounts-payable list, then see how RIAs keep a vendor inventory exam-ready.
Does Regulation S-P require vendor oversight?
Regulation S-P's safeguards rule expects firms to oversee service providers that receive customer information, including incident-notification provisions. The amended rule's compliance dates were December 3, 2025 for larger firms and June 3, 2026 for smaller firms. Our Regulation S-P vendor oversight guide walks through what that oversight looks like in practice, and Compliance & regulations lists the other frameworks we cover. This is educational information, not legal advice — your counsel determines how the rule applies to your firm.
What evidence should we collect during due diligence?
Commonly: SOC reports or equivalent security attestations, written policies, penetration-test summaries, insurance certificates, financial-stability indicators, and answers to a vendor due-diligence questionnaire. Keep each item dated, with a note recording who reviewed it and what your firm concluded.
Can software decide whether a vendor is approved?
No — and it shouldn't. Software can collect evidence, flag gaps, track dates and organize the record, but the decision to engage, conditionally approve or decline a vendor belongs to your firm's authorized reviewer. ThirdNexa never labels a vendor approved; your firm records every decision. See the controls that keep decisions with your firm.
What should we show an examiner who asks about vendor oversight?
A current vendor inventory with risk tiers, dated due-diligence evidence, contract review notes, recorded decisions with the reviewer's name, open findings with owners and due dates, and an activity history showing ongoing monitoring. ThirdNexa exports this record as an evidence pack — see the full oversight workflow.

Related

Regulation S-P vendor oversight, every framework we cover, and pricing.

Educational information only, not legal advice. ThirdNexa does not determine whether a vendor or your firm meets any regulation. Last reviewed October 16, 2026.