Leela
Issues Management
IM-03

Investigate the root cause and set a remediation plan on the severity clock

Policy reference

Issues Management policy, §5, §6

CFPB Supervision and Examination Manual, Compliance Management Review, CMR, Compliance Program: monitoring and corrective action
Requirement

The investigation opens the same business day for a Critical issue, within 1 to 2 business days for High, within 5 for Moderate, and typically within 15 to 30 days for Low. It establishes scope, root cause, impact, and whether a violation or regulatory notification is involved, and it is written up in an Issues Investigation Report. The remediation plan that follows records root cause, corrective action, owner, success criteria, and preventive measures, with remediation windows of 5 to 30 days for Critical, 10 to 30 business days for High, 30 to 60 for Moderate, and 60 to 90 for Low.

Trigger

Event-driven

Investigation opens same day (Critical), 1 to 2 business days (High), 5 (Moderate), 15 to 30 days (Low); the plan follows the investigation

Action

Open the investigation within the window for the rating, gather the facts, write the investigation report, then record the remediation plan in the log and share it with the affected parties.

Evidence
  • Issues Investigation Report

    Facts, scope, root cause, impact, and violation assessment

  • Remediation plan

    Root cause, corrective actions, owner, due dates, success criteria, preventive measures

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 investigation report and the remediation plan from the file for the Compliance Officer to finish and approve.

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?