The study reports gaps in financial institution readiness, which covers the data, processes, people, and internal controls needed for delivery. Weaknesses in co-management, the two firms’ arrangements for decisions, risks, changes, and human review, were accompanied by limited visibility into work performed by delivery teams (Parts 2–5). These findings call for controls that establish preparation before commitment and verify how work is actually completed during delivery.
For new engagements, financial institution readiness should be established before contract approval. Co-management should be established before contract signature. For existing engagements, the same controls provide the basis for identifying gaps and prioritizing corrections. The recommendations and schedule are proposed responses to the findings. Their effectiveness was not tested by the study.


