Approve emergency changes within one day and notify the bank within one

Change Management policy, §9, §10

Where a security incident, a critical system failure, or a regulatory mandate with an immediate deadline requires an urgent change, the process may be accelerated with the approval of the Compliance Officer and the CEO. The Compliance Officer reviews the compliance implications immediately, the approval decision is made within one business day, the sponsor bank is notified within one business day of implementation with full documentation, the change is validated and monitored after implementation, and a root cause analysis and process review follow once the situation is resolved. A regulatory deadline that cannot be met on the routine timeline uses this procedure.

Event-driven

Each emergency change; approval within one business day, bank notice within one business day of implementation

Record the emergency and its justification, obtain the two approvals inside the day, send the bank the full documentation within a business day of implementation, schedule the validation, and complete the root cause review once the emergency is over.

• Emergency change record

  Trigger, justification, Compliance Officer and CEO approvals with times

• Emergency bank notice

  Full documentation and root cause explanation, date sent, hours after implementation

• Root cause analysis

  Cause, process changes, date completed

Compliance Officer

Leela can assemble the emergency notice package from the change record and flag the one-day approval and notice clocks, leaving the approvals to the Compliance Officer and the CEO.

Tell Leela about your company to see whether this applies.