Getting Ahead of Regulatory Findings
From the OCC’s Heightened Standards to the Federal Reserve’s SR 21-7, today’s regulatory expectations are precise, evidence-driven, and increasingly unforgiving. Financial institutions are judged not only on what they fix — but how sustainably they fix it, how they document closure, and how clearly roles are assigned across the lines of defense.
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📌 A 2023 Deloitte survey found that 63% of U.S. financial institutions faced repeat findings on previously remediated issues — often due to unclear controls or weak documentation.
What Is Regulatory Remediation, Really?
At PGMP, we approach remediation with exam-readiness in mind from Day 1. That means:
- Documented root cause analysis
- Sustainable control design
- Milestone-based execution
- Closure testing and control validation
- Executive sign-off and SLOD/IA coordination
- Fully packaged evidence trail
Anatomy of an Effective Exam Readiness Plan
- Inconsistent sprint reporting
- Minimal integration with risk, audit, or compliance gates
- Poor visibility at the program or executive level
- Understand the Playbook
Each regulator — OCC, FRB, NYDFS — has its own language, directives, and expectations. SR letters and prior enforcement actions should be translated into actionable deliverables. - Start with a Gap Assessment
Baseline where you are. What’s documented vs. what’s operational? Where are the single points of failure? - Build the Issues Inventory
Each finding needs a unique ID, accountable owner, control link, risk mapping, milestone plan, and closure strategy. - Stand Up a Remediation PMO
This ensures oversight, cross-functional accountability, and centralized reporting to executives and regulators. - Create Real Documentation
Examiners want formal artifacts — not email threads or workarounds. We create walkthrough decks, testing evidence, and sustainable control narratives.
📊 According to PwC (2022), firms with formalized exam preparation programs reduce the likelihood of MRAs by 42%.
Case Snapshot: OCC Remediation at a Custody Bank
Challenge: A global custody bank was cited for insufficient oversight of RCSAs and ineffective control documentation.
PGMP Response:
- Built a full response index cross-referenced to the OCC’s exam letter
- Rewrote all RCSA templates to align with risk taxonomy
- Delivered a remediation dashboard and closure artifacts
- Led walkthroughs with Internal Audit and Compliance for pre-exam dry run
Outcome: The MRA was closed 3 months ahead of schedule, with no new findings in the following exam cycle.
What Examiners Really Want
Examiners aren’t expecting perfection — they want clarity, accountability, and evidence. You need to answer:
- Who owns the issue?
- What changed?
- How was it tested?
- Where is the evidence?
- Is the fix sustainable?
This is what PGMP builds with every remediation program.