Exception aging before a supervisory visit
A mid-sized payment institution approaching a scheduled supervisory discussion asked for a focused compliance and controls audit on reconciliation and customer remediation. Fieldwork traced three corridors over a six-week period.
Sample testing found refunds stuck beyond five business days without a named escalator. Policy language required faster handling; the queue simply lacked an owner after a reorganization. The findings memo ranked that gap high, listed compensating checks already in place, and proposed a two-step remediation: assign ownership, then clear the aged backlog with a dated attestation to the compliance committee.
Management accepted the severity. The committee pack two months later showed aging below the threshold on the same corridors. The client later commissioned a lighter walkthrough ahead of adding a new remittance product.