Model policy · version 1
Compliance Monitoring & Testing
Prove that your controls work on real activity, not just on paper. Continuous monitoring catches exceptions as they happen; periodic sample-based testing shows examiners and the sponsor bank that each control operated during the period.
What’s in this policy13 sections · Compliance Monitoring & Testing · Read the full policy
9Obligations · things you must do
13Evidence · records that prove it
4Monitoring · checks and deadlines
2Reporting · reports you must send
Does this apply to you?
Answer a few questions and each obligation is marked applies, likely, or needs more information.
Tell Leela about your companyHand over the whole policy
Every obligation in this policy, in one request.
What the policy requires
Automate
Leela can perform the work through your connected systems.
Monitor
Leela can watch for the trigger, keep the clock, and flag what is late.
Prepare for review
Leela can prepare the artifact and hand it to a person for review.
Human required
A person must do the work; Leela can track it and file the evidence.
TriggerContinuous · Maintained as controls change; reviewed with the annual program review
EvidenceControl inventory
TriggerContinuous · Same-day, daily, monthly, and quarterly checks as the program sets
EvidenceMonitoring log, Marketing approval records
TriggerMonthly · Each month, on the prior month’s activity
EvidenceMonthly testing workpaper
TriggerQuarterly · In the last month of each quarter, feeding the quarterly report
EvidenceQuarterly test workpapers, Walkthrough notes
TriggerTwice a year · Twice a year, on the prior six months
EvidenceSemi-annual workpapers
TriggerEvent-driven · On every finding; Critical immediately, High within 5 business days
EvidenceTesting Log entry, Escalation record
TriggerQuarterly · Within 30 days of quarter close
EvidenceQuarterly monitoring and testing report
TriggerAnnual · First quarter of each year
EvidenceAnnual board report, Program review
TriggerEvent-driven · On each sponsor bank review or request
EvidenceBank request log