Building a third-party risk management program from scratch

by :name LexFlag Team · Vendor Risk Management · Mar 12, 2026 · 3 replies Answered

No Reliance on Forum Content. The information, opinions, and discussions shared on this forum are contributed by community members and LexFlag Team and do not constitute professional advice. LexFlag does not endorse, verify, or guarantee the accuracy, completeness, or reliability of any content posted.

User Identity & AI-Generated Content. There is no guarantee that users are using their real names, represent any organization, or express their own personal views. Replies and contributions may be partially or fully generated by artificial intelligence.

Independent Verification Required. You must independently verify any information obtained from this forum before making any decisions. LexFlag, its affiliates, and contributors accept no liability for any loss or damage arising from reliance on forum content.

I've been brought in to build our TPRM program from the ground up. We're a mid-size fintech (~500 employees) with about 200 vendors, and currently there's no formal vendor risk assessment process.

Looking for advice on:

How to tier vendors (critical/high/medium/low)
What to include in a vendor risk assessment questionnaire
How often to conduct reassessments
Any recommended frameworks or templates

Budget is limited, so I need a pragmatic approach rather than a gold-plated solution.

LexFlag Team

Member since Mar 2026

Accepted Answer

I built our TPRM program from scratch 3 years ago. Here's the pragmatic approach that worked:

Tiering (first priority):

Critical: Handles customer data, provides core infrastructure, or would cause major business disruption if unavailable. Probably 10-15 vendors.
High: Accesses internal systems or handles sensitive data. Maybe 30-40.
Medium: General business services with some data access.
Low: Commodity services, no data access.

Assessment approach:

Critical: Full questionnaire + SOC 2 report + on-site/virtual assessment annually
High: Standard questionnaire + SOC 2 or equivalent annually
Medium: Abbreviated questionnaire every 2 years
Low: Self-certification at onboarding only

Framework: Start with the Shared Assessments SIG Lite questionnaire — it's comprehensive but not overwhelming. Customize from there.

Don't try to assess all 200 vendors at once. Start with your critical tier and work down.

Thomas Keller

Fraud Investigator · InsureFirst AG

Member since Apr 2026

-1

3 replies

One addition: make sure you build fourth-party risk awareness into your program from the start. Your critical vendors likely depend on sub-contractors. At minimum, require critical vendors to disclose their key sub-contractors and confirm they have their own vendor management program.

Also, check whether your regulators have specific TPRM expectations. OCC guidance (OCC 2013-29 / 2023-17) is a solid reference even if you're not a bank.

Elena Petrova

Mar 13, 2026 at 10:33 PM

On the tooling side: if budget is tight, a well-structured spreadsheet works fine for the first 6-12 months. Don't fall into the trap of buying an expensive GRC platform before you've defined your process. We started with Excel, refined our approach over a year, and only then invested in dedicated TPRM software (we went with ProcessUnity, but there are several good options).

The tool should serve the process, not the other way around.

Priya Sharma

Mar 15, 2026 at 6:33 AM