Case Study

Second Line of Defense Oversight

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    The Challenge

    A super-regional bank recognized that the process for review of operational procedures was inconsistent.  They also identified that the business line was able to assert closure without a review by the Second Line of Defense.

    The Solution

    • Developed and helped implement a program for the creation, approval and ongoing maintenance of enterprise-wide policies and procedures.
    • Built an efficient, effective, and integrated Tollgate Process certifying the completeness and sustainability of findings remediation – reducing the risk of re-opened and repeat findings.
    • Delivered a program for identifying and remediating operational issues.

    The Benefit

    • Business line and compliance can tell the full story of remediation efforts and apply outcomes to other potentially impacted lines of business.
    • Improved consistency and reduced likelihood of repeat findings, due to formalization of procedure reviews.
    • Ability to validate through a holistic review that all aspects have been addressed.
    • Broader awareness due to mechanism to share findings with other potentially impacted groups; also potential remediation across lines of business.

    A super-regional bank asked Bridgeforce to evaluate their Second Line of Defense oversight over two critical elements:  creation and maintenance of policies and procedures, and the identification and remediation of all findings (line of business and audit).

    Based on a review of the current state of compliance procedure reviews, audit finding closures, and discussions with key stakeholders, the Bridgeforce team developed:

    • Standards for the maintenance and independent review of LOB compliance-related and compliance-owned procedures, reducing the risk of non-adherence to applicable banking laws, rules and regulations, and policies.
    • An efficient, effective, and integrated Compliance Tollgate Process certifying the completeness and sustainability of regulatory compliance-related findings remediation – reducing the risk of reopened and repeat findings