At some point, your bank will find an operation or process isn’t working or failing on intent. When that happens, don’t fall prey to the impulse to fix the wrong problem without looking below the surface for the root cause.
No matter the scenario, your best position is always to self-identify an issue and kick off remediation before a customer or regulator reports a problem. Once external forces step in, the stakes run even higher; you really can’t afford a misstep. Without question, the most common way that banks err is by starting on the wrong foot.
In my front-line experiences, I’ve seen financial institutions work ambitiously on remediating issues only to have regulators assign a failing grade. While no bank wants to be under a regulatory finding’s shadow, working smart and rejecting shortcuts is the only way to deliver the right solution and minimize future risk. With compliance costs expected to more than double and reach 10% of revenue spend by 2022, banks can’t afford to get it wrong.
Here are the steps for an effective remediation:
1.Take a breath – then dive into the deep end
Too often, companies fix what they think is the problem, only to learn that they’ve missed the mark and broken other things along the way. Not understanding the crux of the issue wastes a bank’s time, energy and resources.
If you’re dealing with a regulatory finding, be sure to engage your legal and compliance teams to ensure you understand the issue and solve for exactly what’s at risk, especially for issues with broader scope and breadth. Those leading your remediation plan should dig deeper into root problems by asking “why?” up to five times, peeling off another layer each time as you strive toward the core issue. Apply those questions to your business problem until you’ve identified the precise thing that needs to be fixed.
2. Know how to get from Point A to Point Z
Develop a roadmap to move effectively and efficiently from understanding the issue and identifying root causes to implementing solutions. From aligning on stakeholder engagement to technology resources, no solution happens overnight. Some regulatory remediation activities can take 12 to 18 months to resolve.
3. Make sure everyone’s on the same journey
Nothing derails remediation more than missed consensus on its direction and end goal. Remain focused on actions to fix your root issue, ease regulator or auditor concerns and reduce customer complaints. Engage the right people in the right roles. Involving too many people can water down intent, while involving too few means you might miss capturing relevant insights from key parts of your business.
4. Document your journey
A comprehensive action plan can take time to execute. During that time, people in key roles might leave and business processes, and objectives, technology or regulations could change. Thorough and complete documentation keeps a record of execution activities, action plan or intent changes, and provides evidence of key decisions.
5. You’re not finished until you get an official pat on the back
Did your action plan include time to validate your work? Whether you have a third-line audit, loan review finding or a regulatory ruling, the issuer will return to confirm you solved the right problem completely. Build in solid testing to validate your solution fulfills on its intent, with no side effects that disrupt other processes. Also, if possible, check in with third-line partners regularly or when hitting major milestones to prevent surprises.
Remediation success comes with both the assessor’s endorsement, as well as sustained results from your action plan as evidenced by reporting and monitoring put into place. More importantly, don’t overlook this moment to repurpose your team’s learnings and experiences as the foundation for a repeatable remediation framework. When the next issue arises – and it will – your bank will already have a strategy and blueprint for smart action with minimal risk.