Aligning Credit Policies and Processes to Meet Regulatory Compliance

The Big Picture 

Whether we’re talking about a policy or the processes your bank has put in place to support its intent, the connection between the two often erodes over time.  

It’s rarely on purpose, but, on one hand, evolving market conditions influence policy updates. In other cases, introducing new technology into your protocols or losing veteran team members can mean that processes no longer work the way they initially were designed and launched. 

That was the situation we found at a Top 30 bank that was operating with legacy policies and processes for how it originated and serviced consumer loans, credit cards and deposit accounts. Over the years, the bank had revised its credit documents to meet current regulatory requirements, but it couldn’t validate whether the related processes were still occurring as prescribed. 

That’s why Spinnaker was asked to take a comprehensive assessment of each product’s policies and processes – including significant manual interactions and supporting operational coding – to ensure they were still aligned. And, if they weren’t, we needed to identify the regulatory and operational gaps between the two. 

The Spinnaker Approach 

To launch the initiative, we met with the bank’s credit teams to understand the current processes and documentation, breaking into dedicated workstreams for each product. We started by reviewing each document to determine if it was compliant as written and whether it was efficient. From there, we moved on to gauge whether each process delivered on policy intent. 

We deployed Spinnaker’s data analytics expertise to uncover countless lines of legacy code to break down steps to confirm execution and flag systemic issues. We then used those learnings to prioritize and recommend policy and process document changes to bring operations into regulatory compliance. 

The Client Benefits 

After Spinnaker’s comprehensive analysis of its policies and processes for consumer loans, credit cards and deposits and recommended updates, the bank now has confidence that its products operate within regulatory requirements and that its processes align with internal policies. The bank has a roadmap for remediating issues, starting with the highest-risk items, and opportunities for process automation that will enhance long-term compliance. 

To learn more about how we can assist organizations with ensuring well-managed operations that align with policy and regulatory intent, check out our Credit Policy and Processes case study. By taking a rigorous dive into every product, policy document and process execution, we’re poised to help bankers identify opportunities, particularly within the automation space, to better meet compliance requirements with credit policies and processes.