Data your risk program can rely on.

What it is

The accountability structure for data: who owns it, who maintains it, who may change it, and who answers when it is wrong. Most institutions have a data policy. Fewer have a structure that produces an answer when a regulatory report is found to be misstated.

Designed to sit inside the risk program you already run, rather than alongside it as a second governance apparatus with its own committees and its own vocabulary.

What you receive

A data governance policy and supporting standards written against your regulatory obligations rather than against a maturity model. A roles and accountabilities model naming data owners, stewards, and custodians against actual positions. A governance forum with a charter, defined decision rights, and an escalation path. Data issue management integrated with your existing operational risk issue process. Governance metrics that report whether the structure is working rather than whether it exists.

What it is

An assessment of data risk across the full path the data travels: production and capture, aggregation and transformation, and consumption by the reports, models, and filings that depend on it. Each stage is assessed against the dimensions that determine whether the output can be relied on: accuracy, completeness, timeliness, integrity, and lineage.

Grounded in data risk management at MUFG Union Bank through the US Bank acquisition, where the question was never whether a policy existed but whether the number at the end of the chain could be defended.

What you receive

Critical data element identification, tied to the risks, controls, and regulatory reports that consume them. A stage-by-stage risk assessment across production, aggregation, and consumption, rated against each quality dimension. Control design at the points where a quality failure becomes a loss or a misstatement. Lineage documentation for the elements that carry the most exposure. A data risk framework mapped to your existing operational risk taxonomy, so it is one program rather than two. A gap register with named owners and dates.

What it is

Independent review and challenge through a GRC implementation, migration, or merger. Somebody has to ask whether the risks, controls, and issues that went in are the ones that came out, and it should not be the team being measured on the go-live date.

RSA Archer, IBM OpenPages, and ServiceNow, used as a practitioner inside live programs and across seven enterprise conversions.

What you receive

Requirements written from the risk program outward rather than the platform inward. Data migration review and reconciliation. Configuration challenge before it is locked. Post-conversion validation that the program still functions as designed.

Risk and control data is frequently degraded during a conversion, and the degradation is usually found at the next examination rather than at go-live.

What it is

A standing challenge function for institutions whose internal review sits inside the organization it reviews. Risk assessments, control testing, data quality conclusions, and reported results are examined from outside the chain that produced them.

This is the function performed at MUFG Union Bank through the US Bank acquisition: challenging the work, documenting the disagreement, and escalating what did not resolve.

What you receive

Scheduled challenge of risk assessments, control testing, and data quality reporting against stated evidence standards. Written findings with an audit trail showing what was challenged and how it was resolved. Escalation recommendations with the supporting record. Documentation an examiner or internal audit can follow without a verbal explanation.