Master Moves™

Getting the Feds on Board

Several years after Sarbanes Oxley had become a fact of life, a senior officer at a profitable, highly rated Fortune 500 Bank was struggling with Federal regulators. Despite an experienced team and a compelling vision for building the best auditing department in the U.S., he was unable to earn a "Fully Satisfactory" score for either auditing or security.

Because of the low rating, and despite ample funds, the Bank was unable to pursue its acquisition strategy. Months went by with numerous requests from the regulators, all of which were fulfilled, only to be followed by more requests - and no significant rating change.

The Officer wasn't sleeping well. He believed he was aligned with the Regulators' standards. Reviewing their guidebook, he described how he was implementing each item.

What was missing were clear measures for fulfilling the guidelines. Using the Master Moves™, I showed him how he could lead the regulators to provide the metrics he needed. Initially surprised, he soon saw the point: in the entire guidebook there was not a single measure for how adherence to the guidelines would be assessed. It was all open to interpretation.

The Officer loved the idea of an explicit report card: in this he knew he could excel. I suggested that he follow the Moves™ and ask to collaborate with the regulators to design success measures.

Within 3 months they had explicit measures for every guideline. At the next review, Audit and Security received a "Fully Satisfactory" rating, a "Thank you", and a short list of suggestions about how to earn a "Strong" rating.

The Officer resumed sleeping at night.

The Bank resumed its acquisitions.

 
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