Optimizing TPRM Efficiency Under Increasing Requirements

TPRM requirements have increased tenfold. Your headcount won't. Here's how to close the gap.

In the 90s, vendor management was administrative. One vendor, one service, one contract. Procurement handled it.

That world is gone.

Now a single vendor sells suites of products with different risk profiles. Resellers sit between you and manufacturers. Cloud computing made "critical fourth party" a standard line item. And AI is introducing risks we can predict but haven't fully scoped — data leakage, unexplainable model behavior, liability gaps nobody's tested in court.

The requirements on TPRM have increased tenfold. Your headcount hasn't. And it won't.

The resource request that always gets denied

You can build the business case for more staff. You can show the expanded scope, the regulatory expectations, the risk exposure. Leadership will nod, acknowledge the gap, and approve maybe one additional hire.

That's the reality. So how do you manage a tenfold increase in requirements without tenfold resources?

You stop pretending every vendor deserves the same oversight.

Not every vendor is critical

The FFIEC is explicit: oversight should be commensurate with the vendor's inherent risk to the institution. That's not a suggestion. It's the framework.

But most TPRM programs treat every vendor relationship like it warrants full oversight. The one-time leak repairman gets inventoried alongside your core processor. The facilities vendor who came once gets an annual review cycle.

That's not risk management. That's administrative theater.

Every hour spent on a transactional vendor with zero data access is an hour not spent on the cloud provider hosting your customer data.

The legacy mindset holding us back

Somewhere along the way, TPRM inherited the idea that completeness equals maturity. More vendors tracked, more documentation collected, more boxes checked.

But completeness without prioritization is a trap. You end up with a program that looks comprehensive on paper but spreads oversight so thin that critical vendors get the same attention as the printer repair company.

Mature programs aren't the ones that track everything. They're the ones that focus deeply where it matters and consciously deprioritize where it doesn't.

"Mature programs aren't the ones that track everything. They're the ones that focus deeply where it matters and consciously deprioritize where it doesn't."

Focus is the only way forward

The scope of TPRM will keep expanding. Cloud dependencies, AI integrations, fourth and fifth-party risk — it's not slowing down.

You won't staff your way out of this. The only path forward is ruthless prioritization. Tier aggressively. Automate the low-risk noise. Protect your team's capacity for the vendors who can actually hurt you.

Stop managing vendors. Start managing risk.

RM

About the Author

Risk Management Consultant

With over 15 years of experience in financial services risk management, I help regional banks and credit unions build TPRM frameworks that actually work—without the enterprise overhead. My approach focuses on practical solutions that satisfy regulators while respecting your institution's resources and capabilities.

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