Case Study

Assess and Remediate Regulatory Compliance Gaps



Fortune 500 US Bank and Retail Brokerage


Regulatory Compliance Assessment

Project Overview

Client sought advice and assistance preparing for heightened regulatory expectations applied to larger banks. Reference Point assessed the Client’s readiness for Comprehensive Capital Analysis and Review (“CCAR”), Liquidity Coverage Ratio (“LCR”), and Resolution Planning (“Living Wills”) compliance programs and developed an actionable plan to remedy gaps and areas of weakness.

  • Client was comfortable with its capital position and quantitative metrics, but wanted to assess its ability to pass qualitative examinations, particularly those related to CCAR, LCR, and Resolution Planning
  • While management was aware of multiple areas of weakness, the Bank desired to obtain an outside perspective and learn from experience at larger banks to assess its regulatory compliance gaps, identify a remediation plan and timeline, and estimate the total cost of the readiness program.


  • Reference Point deployed a team led by the former Head of US Credit Stress Testing and CCAR/DFAST at a large US Bank to perform an assessment of the systems and processes supporting CCAR, LCR, and Living Will submission preparation.
  • Reference Point identified core capabilities the bank needed to possess, assessed current state readiness for each capability, and developed detailed recommendations to help the Bank prepare for heightened regulatory scrutiny.
  • Reference Point also prepared a detailed project implement plan and cost model to estimate the cost of compliance as part of the Bank’s growth strategy.


  • The proposed project plan and cost estimates were presented to the Bank’s Executive Committee and used to inform growth and acquisition strategies, hiring decisions, organizational realignment, and budget allocations.
  • Reference Point’s benchmarking assessment and detailed findings and recommendations related to risk management, data governance and system enhancements were utilized by a number of business areas to inform future projects.

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