2025 likely left your organization with a familiar list: exam comments, audit findings, incident reports, and complaint themes that had to be addressed under tight timelines. Most organizations remediate each item, close the loop, and move on – but if that’s where the process ends, you miss a bigger opportunity. Taken together, these issues are one of the clearest indicators of where your compliance program needs to mature next. When you aggregate them and look for patterns – repeat findings, recurring process gaps, vendor-related issues, weak spots in training or documentation – you get a focused view of your real risk and control weaknesses.
Regulators, partner banks, and boards don’t expect perfection; they expect evidence that you understand what 2025 revealed about your program and that you’ve built those lessons into your 2026 plan. This article walks through a practical approach to doing exactly that: collecting and consolidating 2025 issues, identifying themes and root causes, and translating them into concrete 2026 priorities, projects, and monitoring enhancements.
Step 1: Aggregate Your 2025 Inputs
Most organizations have plenty of 2025 “pain points” to learn from, but they’re scattered – exam reports in one folder, audit findings in another, incident logs in a ticketing system, and complaints in yet another tool. Regulators, partner banks, and boards are less interested in isolated fixes and more interested in whether you can see the full picture of where controls broke down. Step 1 is about turning all that fragmented feedback into a single, workable view.
Collect All Relevant Sources
A lot of organizations only focus on exam or audit findings and overlook other signals. For this process to work, you need a deliberate sweep across all 2025 inputs:
- Regulatory and audit results
- Reports of examination, supervisory letters, partner bank reviews.
- Internal audits and external independent reviews (including BSA/AML, sanctions, fair lending, IT/cyber, vendor risk).
- Internal risk and control outputs
- Compliance monitoring and testing results, QA/QC reports, and issue logs.
- BSA/AML independent reviews and model validations, including any tuning or rule-change recommendations.
- Operational and customer-facing signals
- Customer complaints and disputes, including those escalated by partner banks or regulators.
- Operational incidents and near-misses (processing errors, outages, failed changes, security events).
- Vendor and fintech partner oversight reviews, due diligence findings, and performance/SLAs issues.
Build a Single Issues Inventory
Once you’ve gathered the raw material, organize it into one consolidated issues list so you can see everything together instead of in silos:
- Create a standard record for each issue
- Source (exam, audit, monitoring, complaint, incident, vendor review), date identified, area/domain (e.g., BSA/AML, UDAAP, third-party risk), and a concise description.
- Severity or risk rating, impacted product/process/system/vendor, and current status (open, in progress, closed).
- Disaggregate where needed
- If a report describes multiple weaknesses in one paragraph, break them into separate line items so you can spot patterns later.
Normalize and De-Duplicate
With everything in one place, clean the data so it’s usable across the organization:
- Standardize categories and language
- Use consistent labels for areas and high-level causes (policy gap, training gap, system limitation, vendor failure, monitoring/QA weakness, change management breakdown).
- Identify overlaps and repeated issues
- Flag where exams, audits, incidents, or complaints are all pointing to the same underlying process or control.
- Note repeat or carry-over items from prior years so they can be treated as higher-risk themes in your 2026 plan.
The goal of Step 1 is straightforward: create a single, organized inventory of what went wrong in 2025 and where. Once you have that consolidated view, you’re ready for Step 2 – Identifying Themes and Root Causes, where you move beyond individual issues and start seeing the patterns that should drive your 2026 priorities.
2026 Action Steps for Goal #1
To make this goal actionable, consider building these into your 2026 plan:
- Conduct a CMS “health check” in Q1 to identify gaps in governance, documentation, monitoring, and complaints.
- Map key laws, regulations, and risk areas to owners, policies, procedures, and monitoring activities.
- Approve a 2026 compliance monitoring schedule and track completion throughout the year.
- Enhance Board/committee reporting to include metrics, trends, and status of open issues – not just a narrative summary.
Step 2: Identify Themes and Root Causes
Once you’ve pulled all of your 2025 issues into a single inventory, the next step is to stop looking at them as isolated problems and start treating them as data. Regulators, partner banks, and boards care less about whether you had issues – that’s expected – and more about whether you understand the patterns behind them. Step 2 is about turning that consolidated list into a clear set of themes and root causes that will shape your 2026 plan.
Group Issues into Meaningful Categories
Start by organizing your issues in ways that make patterns easier to see. Instead of scanning a long list line by line, slice the data a few different ways:
- By risk area or domain
- Group issues into buckets such as BSA/AML, sanctions, consumer protection/UDAAP, fair lending, deposits, lending, IT/cyber, third-party risk, operational risk, and complaints/servicing.
- Look for areas with a higher concentration of issues or a disproportionate number of high-severity items.
- By process, product, or channel
- Cluster issues tied to the same onboarding flow, product type, payment rail, mobile app journey, or servicing process.
- Pay attention when multiple issues point to a single product or channel – even if each item on its own looks minor.
- By source and recurrence
- Compare what exams, audits, monitoring, incidents, and complaints are each surfacing.
- Flag repeat or carry-over findings from prior years; recurring issues signal deeper weaknesses and will draw more scrutiny.
Define High-Level Themes
Once the issues are grouped, convert those clusters into plain-language themes that describe what is really going wrong across your program:
- Translate clusters into themes
- Examples: “Policies and procedures are not aligned with actual practices,” “Change management is inconsistently applied,” “Vendor oversight is limited to onboarding,” “CDD/EDD standards are not applied consistently,” “Marketing and disclosures are not centrally reviewed.”
- Differentiate symptomatic vs. structural themes
- Symptomatic: one-off documentation gaps or missed steps.
- Structural: patterns that cut across units or products (e.g., lack of standardized procedures, inconsistent training, unclear accountability, weak QA/monitoring framework).
- Prioritize themes based on risk and impact
- Give more weight to themes connected to high-severity issues, regulatory criticism, or activities that could harm consumers or expose the organization to significant BSA/AML or sanctions risk.
Perform Basic Root Cause Analysis
With themes in hand, move from “what happened” to “why it keeps happening.” You don’t need a full-blown forensic exercise, but you do need a defensible view of underlying causes:
- Use simple frameworks (e.g., “5 Whys”)
- Start with the issue (e.g., incorrect disclosures sent) and ask “why” repeatedly until you reach something beyond “human error” (e.g., no formal change management process, unclear ownership, outdated templates, system constraints).
- Focus on control design, not just execution
- Distinguish between failures because a control doesn’t exist or is poorly designed (design gap) vs. failures where the control is sound but not followed (execution gap).
- Link root causes back to governance and infrastructure
- Common underlying drivers: unclear roles and responsibilities, outdated or fragmented policies, insufficient training, lack of centralized QA/monitoring, weak vendor oversight, inadequate system capabilities, or poor change management.
The goal of Step 2 is to move from a list of discrete problems to a small number of clear themes and root causes that explain why your 2025 issues occurred. Those themes become the backbone of your 2026 strategy. With them defined, you’re ready for Step 3 – Translating Themes into 2026 Compliance Priorities, where you’ll turn this analysis into specific goals and projects your organization can execute.
Step 3: Translate Themes into 2026 Compliance Priorities
By now you’ve done the heavy lifting: you’ve consolidated 2025 issues and distilled them into themes and root causes. Step 3 is where that analysis becomes practical – turning those themes into a focused set of 2026 compliance priorities your organization can execute and defend to regulators, partner banks, and the board.
Convert Themes into Clear Strategic Focus Areas
Start by mapping each major theme from Step 2 into a plain-English focus area that can realistically be addressed in 2026:
- Group related themes under broader headings
- Example groupings:
- “Strengthen CMS governance and documentation” (for themes around unclear roles, outdated policies, inconsistent procedures).
- “Enhance BSA/AML and sanctions controls” (for SAR quality, CDD/EDD gaps, sanctions alert handling).
- “Reduce UDAAP and disclosure risk” (for fee-related complaints, unclear marketing, inconsistent disclosures).
- “Improve third-party and fintech oversight” (for vendor gaps, weak monitoring, unclear shared responsibilities).
- Example groupings:
- Limit the number of top priorities
- Aim for a manageable list (e.g., 3–6 core priorities) rather than a long catalog that no one can execute against.
- Tie each focus area to specific risk types
- Note which regulatory or risk categories each focus area addresses (consumer protection, BSA/AML, operational, reputational, etc.) so you can clearly explain the rationale.
Align Priorities with Risk Assessments and External Pressure Points
Next, make sure your proposed priorities line up with what your risk profile and external stakeholders are already telling you:
- Cross-walk themes with risk assessments
- Compare your focus areas to your compliance, BSA/AML, sanctions, fair lending, and enterprise risk assessments.
- Elevate any theme linked to areas already rated “high” or showing upward trends in inherent or residual risk.
- Factor in regulatory and partner feedback
- Give extra weight to themes tied to exam criticism, partner bank concerns, or repeat findings.
- Ask: If a regulator or partner bank reviewed this list, which topics would they expect to see addressed first?
- Consider upcoming events and products
- Build around known 2026 events: scheduled exams, partner reviews, major product launches, system conversions, or M&A activity.
- Where possible, design priorities that will produce visible progress ahead of those milestones.
Define Concrete, Outcome-Based 2026 Goals
Now move from abstract focus areas to specific goals that describe what “better” looks like by the end of 2026:
- State goals in measurable terms
- Examples:
- “Eliminate repeat findings related to outdated policies and procedures by establishing an annual policy review cycle and completing updates for all high-risk areas by Q3 2026.”
- “Improve SAR quality and consistency so that no material SAR-related findings are cited in the next BSA/AML review.”
- “Implement a formal marketing and disclosure review process covering 100% of high-risk campaigns and product terms by mid-2026.”
- Connect goals to controls and infrastructure
- Make clear which elements will change: governance, policies, procedures, systems, training, monitoring, vendor oversight.
- Avoid goals that are purely cosmetic (e.g., “draft a new policy”) without a corresponding change in how work is done.
- Assign ownership at a high level
- Identify the primary accountable owner for each goal (e.g., Compliance Officer, BSA Officer, Head of Operations, Vendor Risk Lead).
- You’ll define project-level owners and timelines in the next step, but high-level accountability should be clear now.
- Examples:
Prioritize What Must Be Done in 2026 vs. What Can Wait
Finally, recognize that not everything can or should be fixed in a single year. A credible plan distinguishes between must-do now and stage for later:
- Rank priorities by risk and feasibility
- High-risk + high-feasibility items should go first.
- High-risk but complex items may need to be broken into phases for 2026 and beyond.
- Mark “2026 commitments” vs. “roadmap items”
- 2026 commitments: items you intend to substantially complete by year-end.
- Roadmap items: areas you will start scoping or piloting in 2026 but plan to complete over a longer horizon.
- Document the rationale
- For anything deferred, note why (e.g., dependency on system change, resource constraints) so you can explain your decisions if asked.
The goal of Step 3 is to move from broad lessons to a short, defensible list of 2026 compliance priorities and outcome-based goals. With those in place, you’re ready for Step 4 – Building a Concrete 2026 Project List, where you’ll break these goals into specific projects, scopes, and timelines your organization can actually deliver.
Step 4: Build a Concrete 2026 Project List
With your 2026 priorities set, the next step is to translate them into specific projects your organization can actually execute. Regulators and partner banks don’t just want to hear that you “plan to strengthen BSA/AML” or “improve vendor oversight” – they want to see defined initiatives with scope, owners, and timelines. Step 4 is about turning each priority into a clear set of projects that will move the needle.
Turn Each Priority into Discrete Projects
Start by breaking each high-level goal from Step 3 into manageable pieces of work. Instead of one broad initiative that never gets off the ground, design several defined projects:
- Define the scope for each project
- Example: a “Policy and Procedure Refresh” project might focus on high-risk areas first (BSA/AML, sanctions, consumer protection/UDAAP, third-party risk) and explicitly include inventorying policies, aligning them to actual practices, and setting review cycles.
- A “Vendor Risk Program Upgrade” project could include building a complete vendor inventory, implementing risk-tiering, and standardizing due diligence and ongoing monitoring templates.
- Align each project to a specific priority and theme
- Make it easy to trace each project back to the themes and root causes you identified (e.g., repeat exam findings, weak change management, inconsistent CDD/EDD).
- Right-size the work
- Projects should be large enough to matter but small enough to complete within a defined timeframe (usually a quarter or two).
Assign Owners, Stakeholders, and Required Support
Once projects are defined, clarify who is responsible for driving each one forward and who needs to be involved:
- Name a single accountable owner
- Assign primary ownership to a role, not a generic “team” (e.g., Compliance Officer, BSA Officer, Vendor Risk Manager, Head of Operations).
- Identify key stakeholders and contributors
- Note which functions must be involved—such as IT, Product, Operations, Legal, InfoSec, Risk, BSA, Vendor Management, or Marketing.
- Recognize where cross-functional coordination will be required (e.g., for changes to onboarding flows, AML systems, or disclosure content).
- Decide where external support is needed
- Flag projects that may require outside expertise or capacity, such as independent BSA/AML reviews, model validations, fair lending assessments, or CMS design work.
Set Timelines, Milestones, and Deliverables
Each project should have a realistic schedule and clear outputs so you can demonstrate progress throughout 2026:
- Define start and target completion dates
- Place projects in specific quarters based on risk, dependencies, and upcoming exams or partner reviews.
- Avoid stacking all high-effort projects in the same quarter; spread them to match available capacity.
- Outline key milestones
- Examples: “complete current-state assessment,” “draft and approve revised procedures,” “implement new checklist/workflow,” “conduct pilot monitoring,” “train staff,” “perform follow-up testing.”
- Specify tangible deliverables
- Policies or procedures updated and approved, new monitoring plans created, dashboards built, training rolled out, vendor reviews completed, validation reports finalized, etc.
Document the Project List in a Simple Roadmap
Finally, pull everything into a single, understandable view that you can use with leadership, the Board, and partner banks:
- Create a 2026 project roadmap
- A one- or two-page view showing each project, its owner, related priority/theme, and planned quarter(s).
- Link projects to your priorities and risk reduction
- For each project, briefly state which risk or regulatory expectation it addresses (e.g., “addresses repeat UDAAP-related complaints on membership fees,” “responds to exam criticism on SAR quality”).
- Make it a living document
- Expect to adjust timelines or add projects as new risks emerge; use this roadmap as the baseline you update and report against during the year.
The goal of Step 4 is to move from “we know what our priorities are” to “here are the specific 2026 projects that will address them, who owns each one, and when they’ll be delivered.” With that project list and roadmap in place, you’re ready for Step 5 – Integrating Lessons into Your CMS, Monitoring, and Training, where you’ll ensure these projects are embedded into the broader compliance framework rather than treated as one-off fixes.
Step 5: Integrate Lessons Into Your CMS, Monitoring, and Training
Once you’ve set priorities and built your 2026 project list, the final step is making sure those improvements aren’t “one and done.” Regulators, partner banks, and boards want to see that lessons from 2025 are built into your day-to-day compliance framework – your CMS, monitoring, training, and governance – not just captured in a project plan.
Update Policies, Procedures, and Risk Assessments
Your written framework should clearly reflect what you learned from 2025 and what you’re changing in 2026.
- Align documentation with actual practices
- Update policies and procedures where issues showed that the documented process didn’t match reality (or didn’t exist).
- Remove outdated steps and add new controls, approvals, or escalation paths that emerged from your 2025 analysis.
- Tie updates to specific themes and issues
- Note in your change logs or document history which exam/audit findings or incidents drove the update.
- This gives you a clear story when regulators ask how you responded to prior criticism.
- Refresh risk assessments to reflect new controls
- Adjust inherent/residual risk ratings where major changes were made (e.g., new monitoring, stronger vendor oversight, improved sanctions controls).
- ake sure your 2026 risk assessments are aligned with the projects you’ve completed and the gaps that remain.
Enhance Monitoring, Testing, and Issue Management
If issues aren’t feeding into your monitoring plan and issue management process, they’ll come back as repeat findings.
- Adjust monitoring plans based on 2025 themes
- Add or refine tests in areas that generated issues last year (e.g., marketing and disclosures, CDD/EDD, sanctions alert handling, vendor oversight).
- Increase frequency or sample sizes for high-risk areas or repeat issues until you see consistent improvement.
- Strengthen QA/QC and second-line testing
- Build checks into operational processes where errors occurred (e.g., account opening, fee assessment, change-in-terms notices, SAR documentation).
- Ensure compliance or risk functions have a clear, documented role in independent testing of those controls.
- Integrate issues into a single tracking and follow-up process
- Use a central log to track findings, remediation plans, owners, and due dates across exams, audits, monitoring, and vendor reviews.
- Include follow-up testing or validation as part of the closure criteria, not just “policy updated” or “training completed.”
Refine Training, Governance, and Reporting
Finally, embed lessons into how you communicate, train, and govern the program so the same problems don’t resurface.
- Target training where root causes pointed to people and process gaps
- Develop focused training or job aids for areas with repeated errors (e.g., SAR narratives, disclosure delivery, exception handling, onboarding flows).
- Use real (anonymized) 2025 examples to make training practical and relevant.
- Incorporate lessons into committee and Board reporting
- Report on themes, projects, and status – not just counts of findings or training completions.
- Show how 2025 issues informed your 2026 priorities and where you are against plan.
- Formalize feedback loops with business units and partners
- Share key lessons and control changes with product, operations, BSA, marketing, and vendor management teams.
Where fintech–bank relationships are involved, ensure both sides understand what changed and why.
How RADD Can Help
Turning 2025 issues into a focused, defensible 2026 plan takes time, structure, and capacity most compliance teams don’t have on top of “business as usual.” RADD helps organizations move from a pile of exam comments and audit findings to a clear story: here’s what surfaced, here’s what it means, and here’s what we’re doing about it.
RADD can support you at every step of this process:
- Build a consolidated 2025 issues inventory
- Gather and normalize findings from exams, internal/external audits, BSA/AML reviews, monitoring, incidents, complaints, and vendor/fintech oversight.
- Create a single, structured issues log that makes patterns and repeat problems easy to see and easy to report on.
- Identify themes and root causes
- Analyze your 2025 issues to surface cross-cutting themes (e.g., weak change management, inconsistent CDD/EDD, gaps in vendor oversight, UDAAP risk in marketing).
- Facilitate root cause analysis so you can explain why issues occurred – not just restate what examiners and auditors already said.
- Define 2026 priorities and roadmap
- Translate themes into a short, risk-based list of 2026 compliance priorities that align with your risk assessments, regulatory feedback, and partner expectations.
- Build a practical roadmap that sequences work by quarter and ties projects to upcoming exams, partner reviews, and product changes.
- Design and execute concrete projects
- Stand up or refresh key components: CMS documentation, BSA/AML and sanctions procedures, complaint and UDAAP frameworks, vendor risk programs, monitoring plans, and Board reporting.
- Provide independent reviews (e.g., BSA/AML, sanctions, consumer protection, third-party risk) tied directly to your 2025 pain points.
- Embed lessons into your CMS, monitoring, and training
- Update policies, procedures, and risk assessments to reflect 2025 lessons and 2026 improvements.
- Enhance monitoring, QA/QA, and training so controls are tested and reinforced, not just written down.
Help you build management and Board reporting that clearly shows how you responded to prior findings and where the program is trending.
Conclusion
Turning 2025’s issues into 2026 opportunities isn’t about creating more work for your team – it’s about organizing the work you already have in a way that reduces risk and tells a clear story.
By aggregating your 2025 inputs, identifying themes and root causes, translating those themes into 2026 priorities, building concrete projects, and embedding the lessons into your CMS, monitoring, and training, you move from one-off remediation to a structured improvement cycle. That’s what regulators, partner banks, and boards expect to see: not perfection, but a disciplined way of learning from what went wrong and proving that the program is maturing.
Done well, this process changes the narrative. Instead of explaining the same findings year after year, you can show how 2025 surfaced specific weaknesses, how those weaknesses drove your 2026 roadmap, and how you’re tracking progress against that plan. It turns exam comments, audit findings, and incidents from pain points into evidence that your organization takes compliance and risk management seriously.
If you don’t have the time or capacity to run this process end-to-end internally, this is exactly where a partner like RADD can help – by turning that stack of 2025 reports into a focused, defensible 2026 plan and the documentation to back it up.
Book a discovery call with RADD here to walk through your current program, pinpoint your highest-impact priorities for 2026, and kick off the year with a clear, examiner-ready plan in hand.