Escalate Critical issues to the chief executive and the sponsor bank within 1 business day

Issues Management policy, §4, §7.1

A Critical issue is reported to the Chief Executive Officer by phone and to the sponsor bank by phone or in person within 1 business day of identification, with a written summary within 2 business days. Interim mitigation starts at once, both parties are updated daily until remediation is under way, the Compliance Officer assesses whether a regulatory notification is triggered, and the issue goes to the board at its next meeting.

Event-driven

Each Critical issue: escalation within 1 business day, written summary within 2, daily updates until remediation is under way

Make the calls within 1 business day, take interim mitigation steps, send the written summary within 2, keep the daily updates going, decide on regulatory notification, and put the issue on the next board agenda.

• Escalation record

  Who was told, by what channel, and when, for the chief executive and the bank

• Critical issue summary

  Written summary sent within 2 business days, with daily updates

• Regulatory notification assessment

  Decision and reasoning, with any notice filed

Compliance Officer

Leela can start the 1-business-day clock at identification, flag the escalation and the written summary as they come due, and keep the daily update cadence.

Tell Leela about your company to see whether this applies.