Third-Party Tech Vendors Under Regulatory Scrutiny: Oversight Expectations in 2026

The Rise of Third-Party Tech Vendors: Compliance Implications in 2026

As registered investment advisers and broker-dealers continue to evolve operationally, many are leveraging third-party technology vendors to streamline client onboarding, automate reporting, integrate AI tools, and enhance communications. While this shift creates efficiencies, it also introduces meaningful regulatory risk; particularly in areas related to supervision, data protection, and business continuity.

Recent SEC and FINRA examination priorities have underscored the importance of documented vendor oversight programs, particularly where third-party tools materially impact advisory services or client disclosures. The message is clear: vendor risk is no longer peripheral, it’s central to compliance infrastructure.

Regulatory Context: Supervision and Resiliency

In its FY 2026 priorities, the SEC reaffirmed its focus on operational resiliency and third-party relationships, including how advisers evaluate, monitor, and document the integrity of vendors that support advisory functions. This emphasis builds on a broader regulatory theme: firms must demonstrate not only technical competence, but also governance over tools and platforms that impact client experience, trading logic, or recordkeeping.

For broker-dealers, FINRA Rule 3110 remains foundational. Where tech platforms influence supervisory or sales practices, particularly via automation or AI, firms must assess whether those platforms meet supervisory standards and are subject to appropriate testing.

Emerging Risk Areas

Several categories of vendor relationships are now drawing increased attention from both regulators and compliance officers:

• AI-Driven Advisory Tools: Platforms offering portfolio recommendations or financial planning outputs based on proprietary algorithms require oversight comparable to any other third-party model input. Firms must understand and disclose their reliance on such logic, especially when client outcomes are materially affected.
• Client Dashboards and Portals: When third-party tools consolidate account data, performance, or reporting, advisers must confirm the accuracy of that data, the security of transmission protocols, and the retention of records under applicable rules (e.g., Rule 204-2).
• Communications and Marketing Tech: Platforms that house books and records or deliver compliant content must be included in vendor risk frameworks. Social media integration, email campaigns, and public websites often touch multiple compliance areas, particularly under the Marketing Rule.
• Delegated Surveillance Tools: Tools claiming to “monitor compliance” may provide false security. Oversight of those platforms, their logic, and exception management protocols is a key examination focus area.

RegComp’s Perspective: Vendor Governance in Practice

At RegComp Financial, we advise clients to approach vendor oversight through a tiered framework aligned with regulatory expectations and operational materiality. As third-party tools become more embedded across CRM, portfolio management, client communications, and compliance technology, it’s essential to distinguish between strategic platforms, integrated tools, and peripheral systems, and to calibrate oversight accordingly.

This includes formal risk classification, appropriate due diligence, periodic reviews, and clearly defined protocols for data protection, recordkeeping, and supervisory integration. Firms should be prepared to demonstrate how vendor relationships are monitored and documented, especially where client data, advisory outputs, or supervisory obligations are involved.

📌 2026 Consideration:

Third-party technology vendors should no longer be treated as passive support tools. Where they influence advisory services, client experience, or operational integrity, they must be governed with the same rigor applied to any core function. Examiners are asking for documentation, make sure yours is ready.

‍RegComp Financial is a leading national compliance consulting firm with offices in Texas and Florida. To read more about RegComp Financial and its services related to investment adviser compliance, please visit https://www.regcompfinancial.com or call (713) 565-8733.