The saying goes that the only constant is change, which is true. In this post-pandemic environment, TCA continues to complete most engagements remotely. Technology advancements have made the process easier, but offsite engagements create different challenges. Please take a moment to review some tips for an efficient, effective TCA remote review.
Ensuring a Successful Remote Review
Pre-Engagement
TCA wants to help you prepare proactively for your upcoming engagement. You’ll be assigned a dedicated Lead TCA Consultant who will be your main point of contact for all TCA communications. Your Lead Consultant will set up a pre-engagement check-in call to discuss the upcoming engagement. Below are some common questions we are asked by Clients as they prepare for an offsite engagement:
How do I provide the documentation for review?
- Option 1: TCA uses a secure cloud environment through ShareFile, our preferred method for uploading large amounts of data. TCA creates folders that mirror our document requests. The process works best when a single bank representative coordinates the document uploading process. However, if necessary, we can arrange access to ShareFile for multiple employees.
- Option 2: We can access your systems remotely via a VPN or directly access your files onsite. For example, TCA is often given access to loan origination systems, such as Encompass or Calyx, so files don’t have to be uploaded to ShareFile, which saves the Bank time when preparing for the review.
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- Allowing us to access your systems remotely requires approvals from your Management and IT Departments. We can work with you and your IT team to set up VPN or direct system access and test these processes before the review.
- Secure email may be an option for a small number of documents but is not recommended for large files.
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How should I organize the documentation?
- You will receive a request list approximately four weeks before the review. The assigned TCA Lead Consultant will establish folders in your secure Client Upload folder in ShareFile that correspond to each functional area included in the review. Items from the request list should be uploaded to the appropriate folder. If you are using your own secure system for TCA to access, please follow the organization of the request list to organized documentation.
Should I only upload PDF documents?
- When possible, please provide searchable files. TCA prefers MS Word or Excel files because they allow us to search the data more efficiently. When providing PDF documents, please use a program that allows you to print directly to a .PDF file from its source document because such files are searchable. Scanning printed documents creates a “picture” of the file, which makes it difficult to find the required review information.
When should I upload the review documents?
- As soon as possible! A prompt delivery allows the Lead Consultant to make additional testing requests and sample selections before the review. Thus, TCA encourages you to upload requested documentation at least two weeks before the engagement. The request list establishes the timeline for specific documents for your engagement.
During the Engagement/Field Work
Your TCA consultant(s) will be scheduled within a specific time frame for fieldwork based upon the scope outlined in the engagement letter. While engagements typically require one week of fieldwork, TCA will estimate the timeframe and detail it in your Engagement Letter, which you must agree to before scheduling. TCA values our client’s time, and we hope you understand our need to complete the fieldwork within the scheduled timeframe. Our engagement letters states, “Inaccurate or incomplete information, or a delay providing information out of TCA’s control may result in an increase in Professional Fees, including a Cancellation Fee.” We aim to avoid charging fees, but we need to ensure we are being good stewards of our client’s time, including the review following your engagement.
- Entrance Meeting – An entrance meeting is critical to ensure a successful review. It’s an opportunity to confirm the engagement scope, discuss how to communicate questions or requests, schedule time for a daily check-in call, schedule an exit meeting, and discuss any open documentation requests. In addition, while the products and services offered by institutions are similar, each client has different product features, services, and acronyms. Hence, a discussion at the outset provides clarity and allows for a smoother engagement.
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- TCA uses Microsoft Teams for audio and video conferencing, which provides both screen sharing and video conferencing. TCA consultants are happy to test connections before an engagement so that your IT department can grant applicable permissions and make any system adjustments that may be needed.
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- Daily Calls/Matrix – Since establishing daily communications is critical, TCA relies on a Daily Communications/Tracking Matrix. This document keeps you up to date on the progress of the review, our findings, and our questions or requests. The Matrix is sent each day to whomever you have designated as the contact or contacts for the review. Many clients find it helpful to set a specific time each day to review the matrix with TCA, while others only reach out if there are questions. If you are new to an offsite review, a daily call may work best. Our goal is avoiding any surprises on the last day of the review by discussing all questions and potential findings throughout the review and before the exit meeting.
- Supporting or Additional Documentation – After the initial documents are uploaded, any additional information requested will be uploaded to a Matrix specific folder in ShareFile. Your Lead Consultant will identify this folder to you. Your time is valuable, and this approach eliminates guesswork about where to locate documentation to address findings questions or requests.
- Ask Questions – In addition to a scheduled call, you can always contact the Lead Consultant by email or phone with any questions. Keep in mind that there’s no such thing as a silly question. Your TCA consultant shares your goal of helping you and your institution identify and manage risk.
Post-Engagement
- Vetting findings – The purpose of the Daily Matrix is to provide an opportunity for your Team to vet findings prior to the exit meeting, which will be scheduled at the end of the engagement. We understand that there are times when staff may be stretched thin and that key business unit leaders may be unable to access information needed to complete the review. We encourage you to discuss such challenges with your Lead Consultant throughout the engagement so we can find the best way to accommodate your circumstances and complete the review on time. Your Lead Consultant will establish on the last day that supporting documentation will be accepted.
- Report and Workpapers – Once the work has been completed, we will provide a written report of our findings. Since examiners also ask to review third-party workpapers, we will provide these to you via encrypted email after the report is finalized.
- Board/Audit Committee Presentation – A great way to demonstrate that our reviews are independent is to have TCA present its report to your Board or Audit Committee. Documenting this in meeting minutes demonstrates strong Board and Management oversight of the compliance function. These presentations typically are done remotely via Teams or Zoom.
Whether your review is onsite or offsite, TCA’s compliance professionals are committed to delivering A Better Way to manage your compliance risk. Contact us at [email protected] or 800-934-7347 today to discuss options for your next review.
