Report non-compliance, data failures, and regulatory criticism to the sponsor bank

Issues Management policy, §2

Three kinds of issue carry their own reporting duty to the sponsor bank regardless of severity: self-identified non-compliance with applicable law, the bank’s policies, or the program agreement is reported promptly; a material data integrity failure is escalated immediately; and regulatory criticism is reported within 5 business days, sooner if material, with the bank holding final approval over any response to the regulator.

Event-driven

Promptly on self-identified non-compliance; immediately on a material data integrity failure; within 5 business days of regulatory criticism

Identify the issue type at intake, send the bank the report the type requires within its window, and route any response to a regulator through the bank for approval.

• Bank notification

  Report sent, date, recipient, and the issue it concerns

• Regulator response approval

  The bank’s written approval of any response to regulatory criticism

Compliance Officer

Leela can draft the bank report from the log entry and flag the window it has to go out in.

Tell Leela about your company to see whether this applies.