COMPLIANCE
Voluntary disclosure demonstrates risk maturity and builds credibility with both reviewers and examiners
Operationalizing a culture of transparent review
Mandating transparency as a core element of governance ensures independent reviews provide maximum strategic value. Below are five leading practices that support effective, credible and regulator-aligned reviews.
1. Pre-review disclosures
Provide a standardized disclosure package that includes:
▪ Audit findings and compliance questions and answers results
▪ Regulatory correspondence or supervisory communications
▪ Current risk assessments and governance documentation
▪ Forthcoming products, partnerships or geographic expansions
Leading institutions go beyond what is asked. Voluntary disclosure demonstrates risk maturity and builds credibility with both reviewers and examiners.
2. Real-time communication protocols
Establish checkpoints for sharing developments during the review. For example:
▪ Notify reviewers of staffing departures or interim appointments
▪ Provide new information about data issues or transaction spikes
▪ Update business plans or risk forecasts that shift the review context
This ongoing dialogue ensures reviewers remain aligned with institutional realities and support more relevant reporting.
3. Reviewer access to all levels
Ensure reviewers can speak directly with:
▪ Senior leadership responsible for oversight
▪ Operational managers implementing controls
▪ Technology and risk staff closest to day-today processes
This holistic access enables reviewers to test assumptions, identify gaps in institutional narratives and incorporate front-line perspectives.
4. Deliberate scoping conversations
Confirm the review scope reflects:
▪ Recent changes to business lines, products or partnerships
▪ Current regulatory focus areas
▪ Known or emerging risk areas within the institution
Scoping alignment ensures resources are used effectively and key risk areas are not overlooked.
5. Emphasis on risk discovery
Shift from validation to diagnosis. Encourage:
▪ Honest reflection on known issues and gray areas
▪ Discussion of risk trade-offs and resource constraints
▪ Inclusion of preliminary findings in board and executive discussions
This approach reinforces that the review is not a judgment ― it is a tool for learning, prioritization and risk ownership.
68 acamstoday. org