Most financial organizations enter exam season knowing they are carrying open issues, documentation gaps, and process inconsistencies – but without a clear, time‑bound plan to close them before regulators arrive. The result is a familiar pattern: last‑minute scrambles to locate workpapers, recreate decisions, and explain why known weaknesses are still in progress, which drains resources and undermines confidence with examiners and the board.
A 90‑day audit readiness sprint changes that dynamic by forcing focus on the handful of actions that most directly affect exam outcomes: consolidating issues, aligning the audit plan to current risks, tightening documentation in high‑risk areas, and rehearsing how the organization will respond to requests. This blog lays out a practical, week‑by‑week playbook that banks and fintechs can use to move from reactive “exam prep” to proactive, risk‑based audit readiness ahead of the 2026 cycle – without trying to rebuild their entire control environment at once.
Week 1 – 2: Establish the Baseline and Ownership
The first two weeks should focus on understanding where the organization actually stands and who is accountable for getting it exam‑ready. Without a clear baseline and ownership, even the best checklists devolve into reactive fire drills instead of a coordinated 90‑day sprint.
Start by compiling existing artifacts in one place: the current internal audit plan, prior exam and audit reports, open issues logs, key policies for high‑risk areas (e.g., AML, consumer protection, IT/cyber), and relevant board or committee materials. This quick inventory allows leadership to see recurring themes, lingering findings, and areas where documentation is thin or scattered across systems and shared drives.
In parallel, designate a single audit‑readiness lead and define an escalation and communication structure that links the first line, compliance, internal audit, and executive management. By the end of Week 2, the organization should have named owners, an updated contact tree, and a central repository (or folder structure) for all 2026 exam‑related materials, giving the rest of the 90‑day plan a solid foundation.
Week 3 – 4: Build a Consolidated Issues and Commitments Inventory
The next two weeks should be devoted to getting a single, accurate picture of all the organization’s open risks, findings, and promises made to auditors and regulators. Without this consolidated view, it is almost impossible to credibly explain to examiners how management prioritizes remediation or to prove that repeat issues are being addressed at the root‑cause level.
Start by pulling issues from every major source: internal audit reports, compliance testing and QC reviews, operational incident logs, consumer complaints and disputes, vendor oversight reviews, and prior regulatory exams or inquiries. Normalize these into one master inventory with consistent fields for risk rating, business owner, function owner, root cause, due dates, interim milestones, and dependencies so leadership can sort and filter by what truly matters most before the 2026 exam cycle.
By the end of Week 4, the goal is to have a risk‑ranked “single source of truth” that clearly flags high‑severity and aging items, along with a short list of “must‑fix before the next exam” issues that will drive the rest of the 90‑day plan. This inventory becomes the backbone for board and committee reporting, exam conversations, and future validation work, demonstrating that the organization knows where its weaknesses are and is treating them systematically rather than reactively.
Week 5 – 6: Align the Risk Assessment, Audit Plan, and Monitoring
With a clear view of issues in place, Weeks 5–6 should focus on making sure the audit and monitoring agenda actually reflects the risks the organization is carrying into the 2026 exam cycle. When the risk assessment, audit plan, and compliance monitoring operate in silos, obvious high‑risk areas can go under‑tested while lower‑risk topics receive disproportionate attention.
Begin by refreshing the compliance and enterprise risk assessments to capture any material changes in products, channels, volumes, customer segments, or third‑party relationships over the last 12–18 months. Then, map those risks directly to the internal audit plan and second‑line monitoring/testing schedule, confirming that higher‑risk areas (such as AML/CFT, consumer protection, IT/cybersecurity, and third‑party risk) have appropriately frequent and deep coverage, and that known issues from your consolidated inventory are driving targeted follow‑up work.
By the end of Week 6, the goal is to have an updated, risk‑based internal audit plan for 2026 and a coordinated monitoring/testing calendar that supports it, with clearly documented rationale for coverage decisions. This alignment provides a defensible story for examiners and the board: the organization understands its current risk profile and has deliberately structured testing and assurance activities to match.
Week 7 – 8: Tighten Documentation and Workpapers in High‑Risk Areas
Weeks 7–8 are about making sure that, where it matters most, your files look and feel “exam‑ready” without needing a last‑minute cleanup. Focus on the 3–5 highest‑risk domains for your organization – typically areas like AML/CFT, consumer protection/UDAAP, IT and cybersecurity, and third‑party/vendor risk – and treat them as your pilot set. In each domain, pull a small sample of recent audits, reviews, or QC checks and evaluate whether the scope, testing steps, sampling rationale, and conclusions are clearly documented and supported by retained evidence.
Standardize templates for these areas so every file answers the same core questions: what was tested, why it was tested (risk link), how it was tested (procedures and samples), what was found, and how issues were rated and escalated. Where you see gaps – missing support, unclear conclusions, or undocumented follow‑up – close them now by adding clarifying memos, indexing evidence, and ensuring that action items tie back to your consolidated issues inventory.
By the end of Week 8, aim to have at least one fully refreshed, exam‑ready file in each high‑risk domain that can serve as a model for future work. These exemplar files not only reduce stress if an exam targets those areas but also give internal teams a concrete benchmark for the level of documentation, clarity, and linkage to risk that leadership expects going into the 2026 exam cycle.
Week 9 – 10: Strengthen Governance, Reporting, and Messaging
Weeks 9–10 should focus on how leadership will “tell the story” of audit readiness to examiners and the board, using clear governance routines and concise reporting. Even if testing and remediation are strong, weak or inconsistent messaging can make the organization appear reactive or disorganized when regulators start asking questions.
Start by building a simple, recurring dashboard that pulls from your consolidated issues inventory and key metrics: high‑severity and aging issues, repeat findings, complaint themes, key control failures, and progress against your 90‑day plan. Use this to brief senior management and the board or relevant committees, ensuring agendas, packets, and minutes clearly document oversight, challenge, and decisions tied to audit readiness and remediation priorities.
In parallel, align your external messaging playbook: who will coordinate exam communications, how request lists are triaged and tracked, and how the organization will respond when regulators ask about specific issues, themes, or delays. By the end of Week 10, leadership should have a standing board/committee pack, a clear communication and escalation protocol, and a consistent narrative that links risks, testing, issues, and remediation into a coherent story for the 2026 exam cycle.
Week 11 – 12: Run an Exam Readiness Drill
The final two weeks should pressure‑test everything built during the 90‑day sprint by simulating a real exam from request list to response package. A structured “mock exam” or tabletop exercise exposes practical gaps in ownership, documentation, and messaging that may not appear on static dashboards or plans.
Start by using a recent or representative exam request list and assigning each item to the person or team responsible for providing documents, data, and narratives. Time how long it takes to locate and assemble workpapers, policies, metrics, and issue status, and note where evidence is missing, inconsistent, or difficult to retrieve. During the exercise, have a facilitator play the role of examiner, asking follow‑up questions about high‑severity issues, repeat findings, and how management validated remediation.
By the end of Week 12, document the lessons learned in a short gap memo that highlights bottlenecks, unclear responsibilities, and documentation weaknesses, then immediately update your request‑response procedures, central repository structure, and role assignments. This closes the 90‑day sprint with a realistic test of readiness and gives leadership concrete actions to further improve before the 2026 exam cycle formally begins.
How RADD Can Help
RADD helps financial organizations get ahead of the 2026 exam cycle by performing independent audits and reviews that surface issues and control gaps before regulators are in the room. Instead of waiting for examiners to identify weaknesses, RADD’s team designs and executes risk‑based audits across high‑priority areas like AML/CFT, consumer protection, IT/cybersecurity, third‑party risk, and the broader CMS to highlight both deficiencies and improvement opportunities.
These audits are structured to mirror regulatory expectations, with clear scopes, robust sampling, and exam‑ready workpapers that document testing, evidence, and conclusions in a way examiners recognize. Findings are consolidated into a practical issues inventory that includes root‑cause analysis and prioritized remediation plans, giving management a clear roadmap to address problems and strengthen controls before they appear in an exam report.
RADD can also perform targeted “pre‑exam” reviews focused on areas likely to receive heightened scrutiny in 2026, validating that prior findings have been effectively remediated and that supporting documentation is complete and easy to retrieve. By engaging RADD to conduct these proactive audits, financial organizations enter the exam cycle with a more accurate view of their risk posture, a documented track record of self‑identification and remediation, and files that are ready to withstand regulatory review.
Conclusion
A focused 90‑day audit readiness sprint can be the difference between a controlled, confident exam experience and another stressful scramble to explain known gaps, incomplete remediation, and scattered documentation. By using each phase of the playbook to consolidate issues, realign the audit plan to current risks, tighten workpapers in high‑risk areas, and rehearse exam responses, financial organizations can enter the 2026 exam cycle with a defensible story and evidence to match.
RADD can strengthen this effort by performing proactive, regulator‑style audits that identify weaknesses and opportunities before examiners do, and by helping management translate those results into prioritized remediation and clearer governance reporting. This combination of a structured 90‑day plan and independent, pre‑exam audit work gives boards and regulators greater confidence that the organization understands its risks, is addressing them systematically, and is ready for deeper supervisory scrutiny in 2026.
Click Here to schedule a discovery call with RADD, to scope a 90‑day pre‑exam audit engagement focused on your highest‑risk areas, surface issues before regulators find them, and ensure your 2026 exam files are truly audit‑ready.