The exam asks what the agent did.
Answer with a receipt.

Banks

NIST controls, model risk management, exam findings

What the reviewer asks for

Ongoing monitoring of the agent action, beyond a model inventory.

What ICA hands them

Runtime evidence of every consequential agent action, sealed and re-performable, so model risk can challenge the action in use, with the inventory kept as it is.

Where to start

One credit or operations path.Model risk or internal audit accepts the evidence package: yes or no.

Beside what you run

An inventory lists the model. ICA's receipt proves what the agent did, who authorized it, and that the record was never edited.

Broker-dealers

SEC, FINRA supervision, books and records (SEC Rule 17a-4)

What the reviewer asks for

A supervisory record of the agent action that a FINRA exam could request.

What ICA hands them

A supervisory record per agent action, signed at decision time, beside the WORM archive.

Where to start

One surveillance or operations path.Supervision accepts the evidence package: yes or no.

Beside what you run

WORM keeps what was stored. ICA proves what the agent did and who authorized it, before anything was stored.

Credit unions

NCUA examination, member data

What the reviewer asks for

Ongoing monitoring of the agent action that an examiner can read.

What ICA hands them

Exam-readable runtime evidence on one member-operations path.

Where to start

One member-operations path.Exam management accepts the evidence package: yes or no.

Beside what you run

ICA starts on one path and one finding, sized to the credit union.

Payments and money transmitters

BSA and AML, state money-transmitter rules, network rules

What the reviewer asks for

Who authorized an agent action on a payment or customer file, and the halt.

What ICA hands them

A held-for-human gate on payment actions, and a signed record of every customer-file touch.

Where to start

One queue, one data class.BSA accepts the evidence package: yes or no.

Beside what you run

The ledger keeps the money. ICA keeps the proof of who let the agent move it.

Mortgage servicers

CFPB servicing rules, unfair practice

What the reviewer asks for

The agent action on a borrower file, who authorized it, and the notice it triggered.

What ICA hands them

No agent denial without a named human authorizer, and every borrower-file action sealed.

Where to start

One servicing path.Compliance accepts the evidence package: yes or no.

Beside what you run

ICA keeps that record, and holds any agent denial for a named human.

Registered investment advisers

SEC, Investment Advisers Act, fiduciary duty

What the reviewer asks for

Advice-agent authorization, and the record exam staff would ask for.

What ICA hands them

Advice-agent actions authorized and sealed, ready for exam staff.

Where to start

One advice path.The chief compliance officer accepts the evidence package: yes or no.

Beside what you run

Each advice-agent action carries a signed record that verifies offline.

Pensions

ERISA, Department of Labor

What the reviewer asks for

A benefit or investment agent action a fiduciary can show.

What ICA hands them

Benefit and investment agent actions with the fiduciary authorizer named in the receipt.

Where to start

One decision path.Fiduciary counsel accepts the evidence package: yes or no.

Beside what you run

The recordkeeper keeps the workflow. ICA proves the agent's step inside it.