Complementing a Large Bank’s Governance Team to Standardize Procedure Documentation

Overview

‍Large banks often have in-house procedure governance teams that document processes and procedures, but they can end up with a siloed approach that makes it difficult for auditors and can lead to inaccuracies and inefficient documentation efforts. For the past two years, F2 helped this large national bank introduce a standard methodology across its business and address misalignments between the documented procedures and actual actions that occurred due to a reorganization.

Challenge

Because many different subject matter experts were documenting procedures in different styles, the bank’s auditors and other readers were having difficulty reviewing and comprehending the procedures. The bank needed to create a more centralized structure and ensure that the procedures used the same template and language regardless of whoever created the documentation. In addition, due to a reorganization, the procedures did not clearly indicate ownership of the control, resulting in frequent internal findings.

Outcomes

1. Standardized the documentation process. F2 reviewed templates and implemented new template standards to ensure that documentation is consistent. We also removed non-departmental tasks and put them in the right area for ownership and accountability. And finally, we aligned the controls properly between the front and the back. This increases efficiency by avoiding duplication of steps and empowers the team to identify more efficiencies in the future.
2. Separated operational steps from the front office procedures. F2 helped delineate roles and responsibilities and align controls using the procedures to make sure that the handoffs to the back office are clear and that efforts to mitigate risk are understood, tested, and not duplicated. This work is also driving various system changes by building the requirements to streamline communication between the front and the back office.
3. Establish governance over fiduciary line of business products. With such a large documentation library, reviewing procedures becomes unmanageable, and procedures are essentially rubber-stamped instead of effectively scrutinized. We gave the bank a framework designed to reduce the number of procedures that are required to be reviewed annually so that they will be able to perform more meaningful reviews.

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