MRA · liquidityresolved
Contingency funding plan did not evidence executable collateral mobilization.
Verify sustainability; do not silently accept prior closure
Private intelligence + nonduplicative follow-on exams
Remember what happened. Reuse what remains valid. Examine what others missed.
Vigil reconstructs the prior examination, MRA, warning, penalty, remediation, and closure chain; suppresses redundant procedures; identifies unexamined risk; and proposes the team order that best matches remaining work.
5
Prior events reconstructed
2
Reusable procedures
4
Uncovered domains
2
Redundant tests suppressed
Follow-on scope compiler
OCC → CFPB · Federal Reserve · FinCEN
| Risk domain | Prior coverage | Inherited issue | Follow-on treatment |
|---|---|---|---|
| liquidity | completed by prior regulator | None open | targeted freshness and delta only |
| credit | completed by prior regulator | None open | targeted freshness and delta only |
| consumer | not comprehensively covered | Open / unverified | high verify and expand |
| BSA/AML | not comprehensively covered | None open | full first review |
| cybersecurity | not comprehensively covered | None open | full first review |
| model risk | not comprehensively covered | None open | full first review |
Issue + resolution history
warning · consumerin_progress
Mortgage servicing complaint escalation was inconsistent.
Escalate as unresolved inherited risk
Expertise-aware sequence
CFPB
Lead: cfpb-a
1 uncovered or elevated domain matches; earliest qualified availability week 1.
FinCEN
Lead: fincen-a
1 uncovered or elevated domain matches; earliest qualified availability week 1.
Federal Reserve
Lead: frb-a
1 uncovered or elevated domain matches; earliest qualified availability week 2.
Private benchmark room
Systemic signals without entity-identifiable data
0
systemic Risk
6
inconsistent Treatment
3
regulatory Arbitrage Leads
0
duplicate Burden Leads
✓ bucketed Outputs Only✓ differencing Queries Blocked