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Article
Legacy Contracts Cannot Carry Tomorrow’s Regulatory Risk
Legacy contracts inevitably fall behind changing regulation, but rewriting agreements is not always the answer. A senior third-party cybersecurity risk executive argues that firms should identify where obligations truly sit, prioritize genuine gaps and combine contracts with continuous monitoring, internal controls and formal risk acceptance.
Aug 31, 2026

Center for Financial Professionals ,
Tags:
Vendor and Third Party Risk
The views and opinions expressed in this content are those of the thought leader as an individual and are not attributed to CeFPro or any other organization
- Legacy contracts
reflect regulations in force when they were signed and inevitably develop
gaps
- Regulatory change
should be anticipated from the RFP and contracting stages
- Not every regulatory
obligation imposed on a financial institution should be transferred to
vendors
- Firms need accurate
inventories to identify and prioritize contracts requiring remediation
- Continuous monitoring
can provide controls where contractual protections are insufficient
- Critical vendor gaps can sometimes be addressed through formal risk acceptance and governance
- Clean, validated supplier data must come before large-scale AI adoption
- Future TPRM models
will increasingly focus on real-time insight and enterprise-wide
enablement
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