Leela
Change Management
CG-02

Complete a compliance review memo for each material change

Policy reference

Change Management policy, §4.3, §5

OCC guidance on new products and services risk management, New products and services, risk assessment before launch
Requirement

For each material change the Compliance Officer completes a detailed compliance review within five business days, covering legal compliance, disclosure updates, fair lending and unfair or deceptive practice risk, data privacy, vendor governance, required documentation and customer communications, and training. Where the change introduces a new vendor or materially changes one, vendor due diligence is completed before approval and recorded in the same memo. The memo ends with a recommendation to approve, approve with conditions, or reject.

Trigger

Event-driven

Each material change, within five business days of triage

Action

Work through each review area against the change request, complete vendor due diligence where a vendor is involved, document the findings, and issue the recommendation before the approval decision.

Evidence
  • Compliance review memo

    Findings by review area, vendor diligence results where applicable, recommendation, date

  • Vendor due diligence file

    Licensing, SOC 2 or equivalent, regulatory history, contract terms checklist

Owner

Compliance Officer

Leela can
Prepare for review

Leela can prepare the artifact and hand it to a person for review.

Leela can draft the memo from the change request and the review checklist, leaving the findings and recommendation for the Compliance Officer to sign.

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?