Leela
Change Management
CG-04

Give the sponsor bank advance notice of medium and high impact changes

Policy reference

Change Management policy, §4.5

Interagency Guidance on Third-Party Relationships: Risk Management, 88 FR 37920 (June 9, 2023), ongoing monitoring
Requirement

The sponsor bank receives written notice of every medium impact change at least ten business days before implementation and of every high impact change at least 30 business days before, unless the bank expressly waives the period. Where a security event or critical incident forces immediate implementation, notice follows within one business day with full documentation. The notice package includes the change request form, the compliance review memo, and the implementation plan. The Company resolves any objection the bank raises before implementing, and does not implement a high impact change over the bank’s objection without escalation to leadership.

Trigger

Event-driven

Each medium change ten business days ahead; each high change 30 business days ahead

Action

Assemble the notice package once the change is approved, send it inside the window for its level, log the bank’s response, and resolve any concern before the implementation date.

Evidence
  • Sponsor bank notice package

    Change request form, compliance review memo, implementation plan, date sent

  • Bank response record

    Questions, objections, resolution, waiver where granted

Owner

Compliance Officer

Leela can
Prepare for review

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

Leela can assemble the notice package from the change file, count the notice window back from the planned date, and flag a change scheduled inside it.

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?