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Desired Capabilities

  • Regulatory Compliance
  • Operational Risk
  • Governance and Policy
  • Process Management

The Situation

As part of an enterprise excellence initiative to resolve regulatory findings, a Top 30 bank needed to review materials to capture all commitments made to its student lending customers. Regulators also expected the organization to ensure that controls were in place for each of these commitments. 

The Challenge

Review nearly 900 student lending documents to identify and inventory customer commitments, then establish easily digestible control guidance for how the business should operate and deliver on what it was communicating to student lending customers. 

Meaningful Outcomes

  • Identified 3,330 commitments, then developed and mapped associated control guidance to ensure the bank delivered on its student lending commitments across all channels. 
  • Navigated successfully through numerous nuances in documents to capture commitments. 

  • Delivered a tracking tool that enabled the bank to conduct future gap analyses on how it executes against commitments and distill data for performance metrics. 

  • Positioned the bank for strong performance in ongoing regulatory reviews. 

  • Developed effective partnerships with bank peers. 

Our Approach

Spinnaker Consulting Group first analyzed nearly 900 documents – ranging from complex contracts to one-page marketing materials provided or exchanged across the life cycle of a student loan – to find and extract any potential commitments to customers. The bank then validated the appropriate commitments. In reviewing the significant volume of documents, our Spinnaker team also focused on identifying where the bank needed to act in direct response to a customer action. The team then developed control guidance that spoke proactively to the bank’s specific actions in response to each commitment. As we assembled validated commitments, our consultants grouped those that were similar and aligned them with a single control guidance to deliver efficiency and simplicity to the initiative and minimize downstream impact.