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Dual-Regulator Convergence: 11-Pillar Architecture for G-SIB Consent Order Remediation
Published Online: November-December 2025
Pages: 202-208
Cite this article
↗ https://www.doi.org/10.59256/ijsreat.20250506030Abstract
Research demonstrates the continuing pressure from both dual regulators in US - OCC and FRB - that has been placed on the largest Global Systemically Important Banks (G-SIBs) after the 2008 financial crisis. This paper provides a unique solution to the Matters Requiring Attention (MRAs) and 2010/2012 consent orders via an 11-pillar remediation structure that resulted in a remarkable 95% on-time closure rate and a very low reopen rate. Using a severity-priority matrix and a tiered governance structure has also significantly reduced residual risk and allowed the banks to avoid large regulatory fines by maintaining an adequate regulatory buffer. The automation of the data center architecture for the framework will also improve regulatory visibility. Key innovations include an efficient change control process, a hybrid execution methodology, and a global delivery model. Overall, lessons learned relate to promoting the cultural alignment of organizations. The expectation is that, in the future, this framework will provide G-SIBs with a strategic compliance advantage, with the expectation that advanced technology and scalability features will be implemented by 2030.
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