Regulatory change log

A regulatory change log is the dated record of every regulatory change an organization has identified, with the decision it took on each and the actions that followed. It is a decision record: one row per change, including the changes judged out of scope and the reasoning behind that judgment. Supervisors ask for this kind of record. When US examiners review a bank's consumer compliance change management, the OCC's Compliance Management Systems handbook lists the information to review: "project management tracking records, applicable committee meeting minutes, adopted policies and procedures related to the change, and monitoring or audit reports for reviews conducted throughout and after the change."

A log that ties those artifacts to each change is the index an examiner needs. The underlying assessment factor comes from the FFIEC's Uniform Interagency Consumer Compliance Rating System (81 FR 79473, 14 November 2016), which rates the effectiveness of an institution's change management processes.

Typical fields include:

• a change ID, the date captured and the source citation with a link to the primary text;
• the issuing authority, jurisdiction, change type and lifecycle stage;
• separate published and effective dates, because conflating them is a common tracking error;
• the applicability decision with its written rationale;
• business impact, affected units, the obligations created, owner, deadline and status;
• an evidence link and the next review date.

The log sits upstream of the obligations register: each accepted change creates or amends obligation rows, and each row should point back to the log entry that caused it. High-impact entries usually trigger a full regulatory change impact assessment. Because the log is itself evidence, edits to it should be traceable, which is easier to show when it lives in a system with a tamper-evident audit log.

A free workbook with a 25-field change log is in our regulatory change tracker spreadsheet.

This entry is general information, not legal advice.