A Critical Finding Lands Two Days Before Renewal

The OCC third-party lifecycle guidance emphasizes risk management commensurate with risk and criticality. The mechanism is proportional response: critical vendors deserve stronger due diligence, but the response should match impact, substitutability, compensating controls, and remediation evidence. Renewal is not a yes/no ritual; it is a risk-treatment decision with governance. In practice, the reviewer should write the dependency, evidence gap, risk treatment, accountable owner, and follow-up trigger in the decision record. That is what makes the decision inspectable after the meeting is over and prevents the team from confusing speed with unmanaged acceptance.

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