Managing consent orders from both the Federal Reserve and the Office of the Comptroller of the Currency (OCC) can be complex. You're juggling two timelines, two sets of requirements, and two approval processes. This template helps you track compliance obligations, document progress, and maintain audit readiness under dual oversight.
Purpose of the Template
This spreadsheet is designed for compliance officers managing AML/BSA program enhancements under dual regulatory oversight. It addresses three key challenges:
Requirement Mapping Across Agencies: When the Fed and OCC cite similar deficiencies with different language, you need to determine which remediation efforts satisfy both and which require separate actions.
Timeline Coordination: Each regulator has its own review schedule. This template ensures you don't complete Fed requirements while falling behind on OCC milestones.
Evidence Organization: During examinations, you must show how specific actions addressed findings from each regulator. This template keeps that evidence organized.
Prerequisites
Before using this template, ensure you have:
- Complete copies of all consent orders and enforcement actions
- Confirmation of your primary regulator for reporting hierarchy
- Contact information for your examination team at each agency
- Access to your institution's project management or compliance tracking system
- Authority to assign remediation tasks across departments
Establish a regular review schedule with executive management. Weekly compliance committee meetings are common during active remediation.
Template Structure
Create a spreadsheet with these columns:
Column A: Requirement ID, Use the regulator's citation format. For Fed requirements, use "FED-[section]-[item number]". For OCC requirements, use "OCC-[section]-[item number]". If a requirement appears in both orders, create separate rows.
Column B: Regulator, FED or OCC
Column C: Requirement Text, Copy the exact language from the consent order.
Column D: Category, Customer Due Diligence, Transaction Monitoring, Suspicious Activity Reporting, Governance, or Independent Testing
Column E: Owner, Name of the person accountable for completion
Column F: Due Date, The deadline specified in the consent order, or your internal target if the order allows discretion
Column G: Status, Not Started, In Progress, Submitted for Review, Regulator Approved
Column H: Completion Evidence, File path or document control number for relevant documentation
Column I: Regulator Feedback, Date and summary of any examination findings or approval letters
Column J: Cross-Reference, Note the corresponding Requirement ID if there's overlap with the other regulator
Column K: Next Action, The specific next step and who's responsible
Add a summary tab with these metrics:
- Total requirements by regulator
- Requirements completed vs. outstanding
- Requirements overdue
- Requirements awaiting regulator approval
- Percentage complete by category
Create a separate tab for examination correspondence. Log every letter, email, or meeting with either regulator, including date, participants, topics, and commitments.
Customization Options
Multiple Consent Orders from the Same Regulator: Add a "Consent Order Date" column to distinguish between actions.
State-Chartered Institutions: Add a third regulator column for your state banking department.
Specialized Business Lines: Add a "Business Unit" column if different divisions face different compliance requirements.
Project Management Software Users: Export this template into your existing system. Preserve the regulator-specific tracking and cross-reference functionality.
Adjust the category taxonomy to match your organizational structure. If your compliance function separates sanctions screening from transaction monitoring, split that category accordingly.
Validation Steps
Before using this template during an examination, verify these elements:
Requirement Completeness: Cross-check every numbered paragraph in both consent orders against your template.
Owner Accuracy: Confirm each assigned owner has accepted responsibility and has the authority to complete the work.
Evidence Accessibility: Test your file paths and document control numbers to ensure quick retrieval.
Cross-Reference Validity: Review overlap mappings with outside counsel or your compliance consultant.
Timeline Realism: Compare internal due dates against your actual completion rate for the past 90 days.
Schedule a monthly reconciliation between this template and your board reports. Your board should see the same completion percentages and outstanding items that appear in your regulatory correspondence.
When one regulator terminates its enforcement action while another remains in effect, keep the closed regulator's requirements visible with a "Regulator Approved - Action Terminated" status. This maintains an audit trail and prevents backsliding on completed efforts.
The Federal Reserve ended its enforcement action against United Texas Bank while the institution remains under an OCC consent order for the same AML/BSA deficiencies. This template helps you prove to one regulator that you've completed requirements while showing ongoing progress to another.
