Every one of the study’s 150 engagements contained a reported departure from intended governance, oversight, or control functions. Bank boards should commission an independent audit of delivery, contain material exposure, and require evidence that corrections operate.
Reported control departures and manual alteration each reached 150 of 150 sampled engagements. The manual-alteration contrast is 100% of engagements versus under 1.3% of pooled disclosure answers. Bank boards should commission an independent portfolio audit covering provider delivery and the bank’s own readiness.