With the FFIEC CAT officially sunset on August 2025, banks are rethinking how they manage cybersecurity oversight. But one area that can’t get lost in the shuffle? Vendor management. In fact, third-party risk is getting more scrutiny, not less, under new guidance.
The Shift:
The FFIEC CAT gave banks a standard lens for assessing cybersecurity. Now, with the move to other frameworks and evolving OCC guidance, banks are expected to build more integrated, risk-based programs; and that includes deeper vendor oversight.
Why Vendor Management Needs More Focus Now:
Examiners aren’t backing off
While the FFIEC CAT may be going away, examiner expectations around third-party oversight are only intensifying. The OCC’s May 2024 Guide for Community Banks adds specific, practical steps for how banks should vet and manage vendor relationships. From due diligence to ongoing monitoring, if institutions don’t have a structured, defensible process in place, they’re likely to face findings in their next exam. That’s why vendor management can’t be treated as a check-the-box exercise; it’s central to regulatory compliance moving forward.
AI and automation increase scrutiny
As more banks adopt AI tools and automated solutions, often delivered by third-party vendors, examiners want to know those models are safe, secure, and well-governed. Under SR 11-7 and other model risk guidance, financial institutions are responsible for validating how vendors manage their own systems, especially if they impact core operations or data. This means vendor reviews need to dig deeper than basic questionnaires. They must include risk assessments, documentation, and validation; which can quickly overwhelm teams still relying on manual tracking and spreadsheets.
Data can’t live in silos
A disconnected approach to vendor management increases institutional risk. If the information about a vendor’s contract, risk level, or system access lives in a spreadsheet that’s not tied to your broader governance program, important signals can be missed. For example, a vendor flagged for access risk may not be caught if that insight doesn’t feed into access management reviews or board reporting. That’s why integrating vendor oversight into a centralized, system-wide process is essential as cybersecurity expectations become more dynamic.
What to Do Next:
Centralize your vendor data
Trying to manage vendor oversight across scattered spreadsheets, shared drives, and email chains is not sustainable as the number of third-party relationships grows. By centralizing your vendor data into a single, structured system, you create visibility across your institution. That means every contract, review, risk score, and renewal date is documented, easy to access, and tied to a specific process. It’s not just about saving time; it’s about creating a defensible audit trail that meets examiner expectations.
Automate reviews and reminders
Even the most diligent teams can fall behind when vendor reviews are manual. Automating review workflows ensures nothing slips through the cracks; including tasks like collecting updated SOC reports, completing risk assessments, and checking insurance coverage. Built-in reminders and approval routing help your team stay on schedule, while reducing the time spent chasing stakeholders or redoing incomplete documentation. The result: more consistent oversight and fewer surprises during exams.
Tie vendor oversight to your broader governance
Vendor management doesn’t live in a vacuum. It impacts, and is impacted by, your institution’s information security, access management, and compliance posture. When vendor reviews are integrated into a broader governance platform, they inform risk assessments, influence access decisions, and feed into board-level reporting. This holistic view is exactly what regulators are looking for and it’s how institutions build resilience in a shifting cybersecurity landscape.
How Finosec Helps:
Our Vendor Governance module and secure AI-Assistant-Regi-powered reviews help institutions:
- Complete risk assessments faster
- Stay ahead of contract renewals
- Maintain audit-ready documentation year-round
- Integrate vendor oversight with system-wide governance – including the transition from the FFIEC CAT to the FINOSEC CAT
How Finosec’s CAT Replacement Streamlines Vendor Management
When the FFIEC CAT began its sunset phase, Finosec didn’t just retire a checklist, we reimagined the tool. Our new CAT replacement goes beyond assessment scores. It’s designed to give banks a living, breathing governance platform that reflects real risk across all areas, including vendor management.
With vendor oversight built directly into the exam readiness dashboard, Finosec helps you connect the dots between third-party risk and your institution’s broader cybersecurity posture. Vendor reviews aren’t buried in isolated folders, they’re embedded into the same workflows you use to prepare for audits, monitor systems, and track action plans. This ensures vendor issues are surfaced alongside other risks so your team can act on them before they become exam findings.
Plus, our CAT replacement ties into Finosec’s Vendor Governance module and Regi Ranger support, helping you:
- Complete vendor risk assessments aligned to CIS Controls
- Automatically log and track due diligence tasks
- Document how vendor access impacts system-level risks
- Keep your board and auditors informed with centralized reporting
So as the old FFIEC CAT fades out, Finosec equips you with something stronger: a dynamic governance system that treats vendor management as a core security function, not a side task.
To see our tool in action, join one of our upcoming demos.
