Nonperforming assets diverged from cohort
94% confidence2.46% versus 1.05% peer median. Three commercial real-estate cohorts explain 81% of the variance.
FDIC RMS §3.112 source recordsCADE challenged
Next best action
Approve the risk-focused scope
Vigil reconciled the authority pack, prior report, call-report variance, open remediation, and CADE dissent. Approve once; the workplan, requests, samples, and workpapers assemble automatically.
Estimated examiner time returned
31.4 hours
46Checks complete
7Requests ready
3Decisions
Zero-brain-power rail
Exception-first review
Only 3 decisions require judgment
Allowance methodology conflicts with board packet
89% confidenceThe Q2 methodology memo applies a qualitative factor not reflected in the approved board schedule.
ASC 3262 conflicting sourcesContrary evidence open
Monitoring backlog exceeds policy threshold
97% confidence24 alerts are older than 30 days; risk distribution indicates a targeted sample of 9 rather than a full population review.
BSA/AML ManualSample prebuiltNo severity assigned