Classify each change and approve it within the clock for its level

Change Management policy, §4.4

Every change is classified low, medium, or high impact from the compliance review. Low and medium changes are approved by the Compliance Officer within five business days, with low changes summarized to the CEO monthly. High changes require joint approval by the Compliance Officer and the CEO within ten business days and board notification where applicable. Implementation does not begin until the approval is recorded and any notice owed to the sponsor bank has run.

Event-driven

Each change after compliance review; five business days for low and medium, ten for high

Assign the classification, obtain the approval the level requires, record the approver and date in the log, and hold implementation until the approval and any bank notice period are complete.

• Approval record

  Classification, approvers, decision, conditions, date

• Monthly low-impact summary to the CEO

  List of low changes approved in the month

Compliance Officer

Leela can keep the approval clock and hold the change until the approvers sign, but the classification and the approval are a person’s call.

Tell Leela about your company to see whether this applies.