Staying Ahead of the Curve: Proactively Managing TPRM Regulatory Compliance

Jun 23
5 min read

Objects and people interact around a "COMPLIANCE" block wall, scales, ruler, and documents. Emphasizes order with checks and files.

Compliance doesn’t wait—and neither should you.

Regulators aren’t sitting idle, and neither are the risks buried in your third-party ecosystem. As more organizations outsource critical services, the scrutiny around how those relationships are managed has grown sharper, faster, and more complex. Vendor oversight is no longer a back-office function; it’s a frontline defense in your regulatory playbook.

Whether it’s cybersecurity, consumer privacy, operational resilience, or responsible banking, compliance expectations now extend well beyond your own four walls. They travel with your data, systems, and customers straight into the hands of your vendors.

So, how do you keep pace without burning out your risk and compliance teams? By treating regulatory alignment as an active, continuous part of your third-party risk program, not a once-a-year fire drill. The good news? You can get ahead of the curve and stay there with the right approach.

Here are five practical strategies to make that happen:

1. Know the Rules—And Where They Apply

You don’t need to memorize every regulatory acronym, but you do need a solid grasp of which ones affect your third-party relationships. That includes direct regulations like:

GLBA, if your vendors access customer financial data.
HIPAA, if they touch health records.
GDPR and CPRA, if you’re dealing with global or California-based personal data.
Plus, there is a growing patchwork of cybersecurity and operational risk standards like NIST, OCC, and FFIEC guidance.

Start with a risk-regulatory mapping exercise. Connect the dots between your critical vendors, their services, and the applicable laws or guidance. Then build a compliance checklist for each category, so you're not scrambling the next time a regulator wants evidence.

2. Make Compliance Part of Your DNA, Not Just a Checkbox

You're likely missing something if your due diligence templates haven’t changed in the last 18 months. Regulatory expectations evolve, and your assessment process should too.

That means asking smarter questions and requiring supporting evidence. A “yes” on a self-assessment doesn’t cut it anymore. Ask for:

Recent SOC reports, penetration tests, or certifications (ISO 27001, PCI-DSS).
Policy documents that reflect specific regulatory controls (like data retention or breach notification).
Contractual language showing compliance with laws like GDPR or HIPAA.

If a vendor claims they’re compliant, they should be able to show you how. And if they can’t? That’s a conversation worth having before an examiner starts asking the same question.

3. Monitor, Document, Repeat

Initial due diligence is only the starting point. Regulatory compliance should be present day-to-day, not just during onboarding.

Set up a monitoring cadence that makes sense for the risk level, quarterly check-ins for your critical and high-risk vendors, and annual refreshes for the rest. Don’t wait for a contract renewal to find out if a vendor has changed sub-processors, moved data centers, or had a cyber event.

Key actions to build into your process:

Trigger-based reviews (e.g., regulatory changes, vendor incidents, service scope shifts).
Control monitoring, especially for data privacy, cybersecurity, and financial controls.
Evidence logging, saving emails, reports, certifications, and attestations. Document as you go, not in hindsight.

Well-organized documentation is not only essential during audits but also demonstrates that your program has meaningful substance.

4. Use Frameworks—and Foundational Guidance—as Your North Star

You don’t need to start from scratch. Established frameworks and regulatory guidance provide the scaffolding your program needs to stay aligned, scalable, and defensible. Used well, they’re more than checklists—they’re strategic tools that guide smart decision-making and help you demonstrate maturity.

A strong foundation starts with the Interagency Guidance on Third-Party Relationships: Risk Management, issued by the OCC, FDIC, and Federal Reserve. This guidance outlines key lifecycle elements—planning, due diligence, contract structuring, ongoing monitoring, and termination—and serves as a gold standard for banks and any organization managing critical vendor relationships.

Not a financial institution? The Third Party Risk Association provides the standard for Third Party Risk Management in their free, comprehensive TPRM 101 Guidebook that will walk you through all phases of the TPRM lifecycle in detail and provide you with practical tools, tips, and examples for its implementation.

Download Here!

Once that foundation is established, you can layer in frameworks tailored to your specific risk domains and industry. For example:

Financial Services:

Use the FFIEC Cybersecurity Assessment Tool (CAT) to benchmark third-party cyber risk, and align your broader program with NIST 800-53 or the NIST Cybersecurity Framework (CSF) to strengthen control mapping and monitoring.

Healthcare:

Look to HIPAA Security and Privacy Rules when evaluating vendors handling protected health information (PHI). Ensure Business Associate Agreements (BAAs) are in place—these are legally required contracts that outline each party’s responsibilities when handling PHI and help ensure HIPAA compliance. Vendor controls should also align with HITECH Act provisions.

Insurance:

Frameworks like NAIC Model Laws and Guidance on Third-Party Administrators (TPAs) help shape due diligence expectations, especially for claims processors, brokers, and customer data handlers.

Technology and Software Supply Chain:

Adopt software-specific frameworks like SLSA (Supply-chain Levels for Software Artifacts) and the NIST Secure Software Development Framework (SSDF) to manage risks from open-source components, CI/CD pipelines, and outsourced developers.

Cross-Industry or Global Operations:

To scale assessments across geographies and vendor types, use certifications like ISO 27001.

The goal here isn’t to follow all frameworks—it’s to select the ones that make sense for your organization, risk profile, regulatory exposure, and operational reality.

By combining lifecycle-based regulatory guidance with targeted frameworks, you build a tailored and resilient TPRM program. This shows regulators, auditors, and your own leadership that you understand not just the “what” but the “why” behind your oversight approach.

Proactive risk programs stand out by effectively anticipating potential challenges and implementing strategic measures to mitigate them before they escalate.

5. Make TPRM Everyone’s Business

Even the best-designed compliance framework will fall apart if no one uses it. Training and communication aren’t optional—they’re how you operationalize your program.

Risk and compliance teams can’t do it alone. Your business stakeholders need to understand:

When a vendor relationship triggers regulatory requirements.
What documentation or approvals need collection.
How to recognize and escalate red flags.

Keep it simple, repeatable, and relevant. Offer live sessions, recorded refreshers, or just-in-time guidance during intake or onboarding. Compliance works best when built into the workflow, not bolted on as an afterthought.

Final Word: Stay Ready So You Don’t Have to Get Ready

Proactive regulatory compliance isn’t about predicting the future but building the muscle to adapt. When your program is designed to flex, monitor, and evolve, you’re not just reacting to audits or enforcement actions. You’re leading with confidence, clarity, and control.

And that’s what true TPRM maturity looks like.

MEMBER EXCLUSIVE

To learn more on this topic, watch our June TPRM Webinar, “Staying Compliant: Proactively Addressing New Regulations.” This roundtable focused on proactive strategies to navigate the dynamic regulatory landscape impacting third-party risk management.

Watch Now!

AUTHOR BIO

Woman with wavy brown hair smiling warmly against a plain gray background. She appears happy and approachable.

Hilary Jewhurst

Sr. Membership & Education Coordinator at TPRA

Hilary Jewhurst is a seasoned expert in third-party risk and risk operations, with nearly two decades of experience across financial services, fintech, and the nonprofit sector. She has built and scaled third-party risk programs from the ground up, designed enterprise-wide training initiatives, and developed widely respected content that helps organizations navigate regulatory complexity with clarity and confidence.

Known for turning insight into action, Hilary’s thought leadership and educational work have become go-to resources for professionals looking to mature their TPRM programs. She regularly publishes articles, frameworks, and practical guides that break down complicated risk topics into meaningful, accessible strategies.

Hilary recently joined the Third-Party Risk Association (TPRA) as a staff member, supporting industry-wide education, peer learning, and advancing best practices. She is also the founder of TPRM Success, a boutique consultancy that helps organizations strengthen their third-party risk management capabilities through targeted training, tools, and strategic guidance.