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OSFI of Canada Guideline B-10 Compliance

Guideline B-10 and Third-Party Risk Management

The Canadian Government Office of the Superintendent of Financial Institutions (OSFI) has issued a draft of Third-Party Risk Management Guideline B-10, which addresses the operational and financial risks associated with vendor and supplier relationships.

Guideline B-10 sets expectations for federally regulated financial institutions (FRFIs) to manage risks associated with third-party arrangements. It is applicable to all FRFIs, except for foreign bank branches and foreign insurance company branches.

The guideline also expands the definition of a third party to include more entities like independent professionals, brokers, and utilities, and recommends including all types of third parties in risk assessments.

Driving these new requirements is the shift from materiality to criticality – where a third party performs a function that is integral to the FRFI’s provision of a significant operation, function or service, requiring a dual-pronged approach where risk and criticality inform the nature and extent of due diligence activities.

Relevant Requirements

  • Clear governance and accountability structures with comprehensive risk strategies and frameworks in place to contribute to ongoing operational and financial resilience

  • Identify and assess risks posed by third parties

  • Manage and mitigate risks posed by third parties within the FRFI’s Risk Appetite Framework

  • Continually monitor and assess third-party performance, and proactively address risks and incidents

  • The FRFI’s risk management program is dynamic and actively captures and appropriately manages a range of third-party arrangements and interactions

The OSFI B-10 Third-Party Compliance Checklist

Learn how to meet third-party assessment and monitoring requirements in OSFI Guideline B-10.

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Complying with OSFI Guideline B-10

Guideline B-10 presents five expected outcomes for FRFIs to achieve through managing third-party risk. These outcomes are meant to contribute to the FRFI’s operational and financial resilience and help safeguard its reputation. Integrating contract lifecycle management systems with existing risk and procurement solutions will support contracting requirements such as rights and responsibilities of each party throughout its lifecycle, as expected by OSFI.

Supporting the five expected outcomes are 11 principles that OSFI describes as best practices for third-party risk management. The summary table below maps Prevalent Third-Party Risk Management Platform capabilities to these 11 principles.

NOTE: This table should not be considered comprehensive, definitive guidance. Consult your auditor for a complete list of requirements.

OSFI Guideline B-10 Principles How We Help

Outcome 1: Governance and accountability structures are clear with comprehensive risk strategies and frameworks in place to contribute to ongoing operational and financial resilience.

Principle 1: “The FRFI is ultimately accountable for all business activities, functions, and services outsourced to third parties and for managing the risks related to third-party arrangements.”

Principle 2: “The FRFI should establish a third-party risk management framework (TPRMF) that sets out clear accountabilities, responsibilities, policies, and processes for identifying, managing, mitigating, monitoring, and reporting on risks relating to the use of third parties.”

Prevalent partners with you to build a comprehensive third-party risk management (TPRM) program based on proven best practices and extensive real-world experience.

Our experts collaborate with your team on defining and implementing TPRM processes and solutions; selecting risk assessment questionnaires and frameworks; and optimizing your program to address the entire third-party risk lifecycle – from sourcing and due diligence, to termination and offboarding.

As part of this process, Prevalent can help you define:

  • Clear roles and responsibilities (e.g., RACI)
  • Third-party inventories
  • Risk scoring and thresholds based on your organization’s risk tolerance
  • Assessment and monitoring methodologies based on third-party criticality
  • Fourth-party mapping
  • Sources of continuous monitoring data (cyber, business, reputational, financial)
  • Key performance indicators (KPIs) and key risk indicators (KRIs)
  • Governing policies, standards, systems and processes to protect data
  • Compliance and contractual reporting requirements against service levels
  • Incident response requirements
  • Risk and internal stakeholder reporting
  • Risk mitigation and remediation strategies

Outcome 2: Risks posed by third parties are identified and assessed.

Principle 3: “Before entering a third-party arrangement—and, periodically thereafter, proportionate to the level of risk and criticality of the arrangement—the FRFI should identify and assess the risks of the arrangement. Specifically, the FRFI should conduct risk assessments to decide on third-party selection; (re)assess the risk and criticality of the arrangement; and plan for adequate risk mitigation and oversight.”

Prevalent centralizes and automates the distribution, comparison, and management of requests for proposals (RFPs) and requests for information (RFIs). Our solutions also deliver business, reputational, financial, and data breach risk insights to inform and add context to vendor selection decisions.

Prevalent moves each selected vendor into contracting and/or onboarding due diligence phases, automatically progressing the vendor through the third-party lifecycle.

Prevalent features a library of more than 100 pre-built templates for ongoing third-party risk assessments. These are integrated with native cyber, business, reputational, and financial risk monitoring capabilities, which continuously validate assessment findings and fill gaps between assessments.

Built-in remediation recommendations ensure that third parties address risks in a timely and satisfactory manner.

Principle 4: “The FRFI should undertake due diligence prior to entering contracts or other forms of arrangement with a third party, and on an ongoing basis proportionate to the level of risk and criticality of the arrangement.”

Prevalent offers a pre-contract due diligence assessment with clear scoring based on eight criteria to capture, track and quantify inherent risks for all third parties. Criteria includes:

  • Type of content required to validate controls
  • Criticality to business performance and operations
  • Location(s) and related legal or regulatory considerations
  • Level of reliance on fourth parties (to avoid concentration risk)
  • Exposure to operational or client-facing processes
  • Interaction with protected data
  • Financial status and health
  • Reputation

From this inherent risk assessment, your team can automatically tier suppliers; set appropriate levels of further diligence; and determine the scope of ongoing assessments.

Rule-based tiering logic enables vendor categorization using a range of data interaction, financial, regulatory and reputational considerations.

Prevalent features a library of more than 100 pre-built templates for third-party risk assessments. Assessments can be conducted at the time of contract renewal or at any required frequency (e.g., quarterly or annually). Assessment questionnaires can be globally focused or regional to address unique legal or operational requirements.

Prevalent delivers built-in remediation recommendations based on risk assessment results. These are backed by workflow and task management capabilities to ensure that third parties address risks in a timely and satisfactory manner.

Integrated, native cyber, business, reputational, and financial risk monitoring capabilities flag material changes between periodic assessments and can trigger notifications, follow-up assessments, or other actions.

Principle 5: “The FRFI should assess, manage, and monitor the risks of subcontracting arrangements entered by third parties, including the impact of these arrangements on concentration risk.”

Prevalent can identify fourth-party and Nth-party subcontracting relationships by conducting a questionnaire-based assessment or by passively scanning the third party’s public-facing infrastructure. The resulting relationship map depicts information paths and dependencies that could expose your environment to risk.

Suppliers discovered through this process are continuously monitored to identify financial, ESG, cyber, business, and data breach risks, as well as for sanctions/PEP screening.

This approach provides insights to address potential technology or geographic concentration risk.

Outcome 3: Risks posed by third parties are managed and mitigated within the FRFI’s Risk Appetite Framework.

Principle 6: “The FRFI should enter into written arrangements that set out the rights and responsibilities of each party.”

Prevalent centralizes the distribution, discussion, retention, and review of vendor contracts. It also offers workflow capabilities to automate the contract lifecycle from onboarding to offboarding. Key capabilities include:

  • Centralized tracking of all contracts and contract attributes such as type, key dates, value, reminders, and status – with customized, role-based views
  • Workflow capabilities (based on user or contract type) to automate the contract management lifecycle
  • Automated reminders and overdue notices to streamline contract reviews
  • Centralized contract discussion and comment tracking
  • Contract and document storage with role-based permissions and audit trails of all access
  • Version control tracking that supports offline contract and document edits
  • Role-based permissions that enable allocation of duties, access to contracts, and read/write/modify access

Principle 7: “Throughout the duration of the third-party arrangement, the FRFI and third party should establish and maintain appropriate measures to protect the confidentiality, integrity and availability of records and data.”

Prevalent delivers a centralized, collaborative platform for conducting privacy assessments and mitigating both third-party and internal privacy risks. Key data security and privacy assessment capabilities include:

  • Scheduled assessments and relationship mapping to reveal where personal data exists, where it is shared, and who has access – all summarized in a risk register that highlights critical exposures
  • Privacy Impact Assessments to uncover at-risk business data and personally identifiable information (PII)
  • Vendor assessments against GDPR and other privacy regulations via the Prevalent Compliance Framework (PCF) – reveals potential hot spots by mapping identified risks to specific controls
  • GDPR risk and response mapping to controls. Includes percent-compliance ratings and stakeholder-specific reports.
  • A database containing 10+ years of data breach history for thousands of companies – includes types and quantities of stolen data; compliance and regulatory issues; and real-time vendor data breach notifications
  • Centralized onboarding, distribution, discussion, retention, and review of vendor contracts – ensures that data protection provisions are enforced from the beginning of the relationship

Principle 8: “The FRFI’s third-party arrangements should allow the FRFI timely access to accurate and comprehensive information to assist it in overseeing third-party performance and risks. The FRFI should also have the right to conduct or commission an independent audit of a third party.”

With Prevalent, auditors can establish a program to efficiently achieve and demonstrate compliance. The solution automates third-party risk management compliance auditing by collecting vendor risk information, quantifying risks, recommending remediations, and generating reports for dozens of government regulations and industry frameworks.

Prevalent automatically maps information gathered from control-based assessments to ISO 27001, NIST, GDPR, CoBiT 5, SSAE 18, SIG, SIG Lite, SOX, NYDFS, and other regulatory frameworks, enabling you to quickly visualize and address important compliance requirements.

Principle 9: “The FRFI’s agreement with the third party should encompass the ability to deliver operations through a disruption, including the maintenance, testing, and activation of business continuity and disaster recovery plans. The FRFI should have contingency plans for its critical third-party arrangements.”

Prevalent automates the assessment, continuous monitoring, analysis, and remediation of third-party business resilience and continuity – while automatically mapping results to NIST, ISO, and other control frameworks.

To complement business resilience assessments and validate results, Prevalent:

  • Automates continuous cyber monitoring that may predict possible third-party business impacts
  • Accesses qualitative insights from over 550,000 public and private sources of reputational information that could signal vendor instability
  • Taps into financial information from a global network of 2 million businesses to identify vendor financial health or operational concerns

This proactive approach enables your organization to minimize the impact of third-party disruptions and stay on top of compliance requirements.

The Prevalent Platform includes a comprehensive business resilience assessment based on ISO 22301 standard practices that enables organizations to:

  • Categorize suppliers according to their risk profile and criticality to the business
  • Outline recovery point objectives (RPOs) and recovery time objectives (RTOs)
  • Centralize system inventory, risk assessments, RACI charts, and third parties
  • Ensure consistent communications with suppliers during business disruptions

When a termination or exit is required for critical services, Prevalent leverages customizable surveys and workflows to report on system access, data destruction, access management, compliance with relevant laws, final payments, and more. The solution also suggests actions based on answers to offboarding assessments and routes tasks to reviewers as necessary.

Outcome 4: Third-party performance is continually monitored and assessed, and risks and incidents are proactively addressed.

Principle 10: “The FRFI should monitor its third-party arrangements to verify the third party’s ability to continue to meet its obligations and effectively manage risks.”

Prevalent continuously tracks and analyzes external threats to third parties. The solution monitors the Internet and dark web for cyber threats and vulnerabilities, as well as public and private sources of reputational, sanctions and financial information.

All monitoring data is correlated to assessment results and centralized in a unified risk register for each vendor, streamlining risk review, reporting and response initiatives.

Monitoring sources include:

  • 1,500+ criminal forums; thousands of onion pages; 80+ dark web special access forums; 65+ threat feeds; and 50+ paste sites for leaked credentials — as well as several security communities, code repositories, and vulnerability databases covering 550,000 companies
  • A database containing 10+ years of data breach history for thousands of companies around the world
  • 550,000 public and private sources of reputational information, including M&A activity, business news, negative news, regulatory and legal information, operational updates, and more
  • A global network of 2 million businesses with 5 years of organizational changes and financial performance, including turnover, profit and loss, shareholder funds, etc.
  • 30,000 global news sources
  • A database containing over 1.8 million politically exposed person profiles
  • Global sanctions lists and over 1,000 global enforcement lists and court filings

Principle 11: “Both the FRFI and its third-party should have documented processes in place to effectively identify, investigate, escalate, track, and remediate incidents to ensure ongoing operational and financial resilience and maintain risk levels within the FRFI’s risk appetite.”

Prevalent enables your team to rapidly identify and mitigate the impact of third-party vendor incidents by centrally managing vendors, conducting event assessments, scoring identified risks, and accessing remediation guidance.

Outcome 5: The FRFI’s risk management program is dynamic and actively captures and appropriately manages a range of third-party arrangements and interactions.

Results from the Prevalent inherent risk assessment enables you to tier suppliers, set appropriate levels of further diligence, and determine the frequency and scope of subsequent assessments.

Rule-based tiering logic enables vendor categorization based on a range of data interaction, financial, regulatory and reputational considerations. Rules apply to all third parties, regardless of contract status.

You can also continuously monitor non-contract vendors against cyber threats and vulnerabilities, as well as public and private sources of reputational, sanctions and financial information to catch potential problems before they escalate.

Navigate the TPRM Compliance Landscape

The Third-Party Risk Management Compliance Handbook reveals TPRM requirements in key regulations and industry frameworks, so you can achieve compliance while mitigating vendor risk.

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