Leela
Change Management
CG-01

Register every change request and triage it within three business days

Policy reference

Change Management policy, §4.1, §4.2

CFPB Supervision and Examination Manual, Compliance Management Review, CMR, Compliance Program (policies and procedures)
Requirement

Every proposed change is submitted on a change request form, registered in the change management log with a unique identifier, and triaged by the Compliance Officer within three business days of intake. The triage decides whether the change is material, considering regulatory implications, customer impact, compliance risk, operational impact, and whether the sponsor bank or a vendor is involved. A change found not material is logged as low impact; a material change proceeds to compliance review.

Trigger

Event-driven

Each change request, within three business days of intake

Action

Log the request with an identifier, work through the five triage questions, record the materiality decision and its reasons, and route the change to review or close it as low impact.

Evidence
  • Change request form

    Description, rationale, affected areas, timeline, owner, preliminary impact

  • Triage record

    Change identifier, materiality decision, reasons, date decided

Owner

Compliance Officer

Leela can
Human required

A person must do the work; Leela can track it and file the evidence.

Leela can keep the three-day triage clock and file the decision, but a person decides whether the change is material.

Applies

Tell Leela about your company to see whether this applies.

Status
Setup needed

Tell Leela how you handle it today, or hand it over: see what’s next.

What’s next?