#	Risk_Taxonomy_Level_1	Risk_Taxonomy_Level_2	Metric	Indicator	Signal_Source	Metric_Threshold	Metric Data Source	Executive	2nd LOD	1st LOD - Business Owner	1st LOD - Branch	Comments	
1	ALL	ALL	"# or % of allegations of employee involvement in sales practice misconduct (by region, product etc.)"	KRI	Investigations					x	x		
2	ALL	ALL	% of employee turnovers by branch or region	KRI	Employee Separation			x	x	x	x		
3	ALL	ALL	# of sales practices trainings by delinquency (30-60-90 days)	KPI	Employee Training				x	x	x		
4	All	ALL	# of customer complaints that remain unresolved related to product dissatisfaction	KRI	Customer Complaints				x	x	x		
5	ALL	ALL	"# of bankers who received coaching, counseling, reprimands, warning, and/or written warning for S.P misconducts"	KRI	Investigations			x	x				
6	ALL	ALL	% of involuntary employee separation due to S.P. related employee misconduct	KRI	Employee Separation			x	x	x			
8	All	ALL	Customer feedback by risk taxonomy topic	KPI	Customer Complaints					x	x		
9	ALL	ALL	"Investigation by status (No action, open, pending, resulted in action)"	KPI	Investigations					x	x		
10	ALL	ALL	"% or # of sales targets that are barely but consistently met and variations across regions, business units and individuals"	KPI	Sales Incentives Program				x	x	x		
11	Employee Misrepresentation to Bank	Falsification of accounts	# of accounts closed with the account closure reason of account opened in error without any explanation as to what the error was	KRI	Acct Activity (Open/Close/Fund)				x	x	x		
12	Employee Misrepresentation to Bank	Falsification of accounts	# of accounts opened and closed by the same banker	KRI	Acct Activity (Open/Close/Fund)				x	x	x		
13	Employee Misrepresentation to Bank	Falsification of accounts	"% approval rates, look for outliers"	KPI	Sales Incentives Program				x	x	x		
14	Employee Misrepresentation to Bank	Falsification of accounts	# of colleagues with non-typical spread of loan type more longer term over shorter term loans compared to average	KPI	Sales Incentives Program				x	x			
15	Employee Misrepresentation to Bank	Falsification of accounts	# of customers still on variable rollover product 6/12 months after rate expires	KPI	Acct Activity (Open/Close/Fund)				x	x			
16	Employee Misrepresentation to Bank	Falsification of accounts	"# of transactions with a high accept rate, but low Call Handling Time"	KPI	Acct Activity (Open/Close/Fund)				x	x	x		
17	Employee Misrepresentation to Bank	Falsification of Bank records / Fictitious Customer/ Falsifying customer information	Age of customers meets minimum age requirement or the customer provided signature when opening an account 	KPI	Investigations					x	x		
18	Employee Misrepresentation to Bank	Falsification of Bank records / Fictitious Customer/ Falsifying customer information	# or % of accounts that failed the credit check to open the account but were still opened	KRI	Acct Activity (Open/Close/Fund)				x	x			
20	Employee Misrepresentation to Bank	Falsification of Bank records / Fictitious Customer/ Falsifying customer information	"# of accounts that list incorrect or illogical email addresse and mail address (branch, employee or other invalid email address not match customer profile), incomplete account information(lack of entries for name, DOB, identification number) in the application process"	KRI	Acct Activity (Open/Close/Fund)				x	x	x		
22	Employee Misrepresentation to Bank	Falsification of Bank records / Fictitious Customer/ Falsifying customer information	# of follow-ups documented in relation to # of customer complaints	KPI	Customer Complaints					x	x		
23	Employee Misrepresentation to Bank	Falsification of Bank records / Fictitious Customer/ Falsifying customer information	"% of accounts with change in profile information (email, address, pin etc. )"	KPI	Acct Activity (Open/Close/Fund)				x	x	x		
24	Employee Misrepresentation to Bank	Falsification of Bank records / Fictitious Customer/ Falsifying customer information	# or % of accounts opened with nothing scanned/missing   documents per segment/ channel/ employee	KRI	Acct Activity (Open/Close/Fund)				x	x	x		
25	Employee Misrepresentation to Bank	Falsification of Bank records / Fictitious Customer/ Falsifying customer information	# or % of offer accepts that occurred on a different date from the call date 	KPI	Acct Activity (Open/Close/Fund)					x	x		
26	Employee Misrepresentation to Bank	Incentive Manipulation	"# of transactions with a high offer rate, but low conversion rate"	KPI	Acct Activity (Open/Close/Fund)					x	x		
27	Employee Misrepresentation to Bank	Misrepresentation of incentives / fee waivers	"# of account applications that were started and not completed, including timing of account application start date and incentive plan timing"	KPI	Acct Activity (Open/Close/Fund)					x	x		
28	Employee Misrepresentation to Bank	Misrepresentation of incentives / fee waivers	# of accounts opened through a sales practice incentive program	KPI	Sales Incentives Program			x		x	x		
29	Employee Misrepresentation to Bank	Misrepresentation of incentives / fee waivers	"# of accounts opened towards the end of an incentive period, trend in sales by  business units, close to the end of the month/quarter when sales targets are measured"	KRI	Sales Incentives Program			x		x	x		
30	Employee Misrepresentation to Bank	Misrepresentation of incentives / fee waivers	# of accounts/products sold with a disproportionately high number of accepts within the first and last few days of the incentive period	KRI	Acct Activity (Open/Close/Fund)				x	x	x		
31	Employee Misrepresentation to Bank	Misrepresentation of incentives / fee waivers	# of credit cards product fee refunds - rate of refunds per employee each month	KPI	Acct Activity (Open/Close/Fund)			x		x			
32	Employee Misrepresentation to Bank	Misrepresentation of incentives / fee waivers	# of credit Cards product interest refunds - rate of refunds per employee each month	KPI	Acct Activity (Open/Close/Fund)				x	x			
33	Employee Misrepresentation to Bank	Misrepresentation of incentives / fee waivers	% accounts closed after opened and funded account or after the associated sales person obtained sales bonus	KRI	Acct Activity (Open/Close/Fund)			x	x	x			
34	Employee Misrepresentation to Bank	Misrepresentation of incentives / fee waivers	% accounts dormant after opened and funded account or after the associated sales person obtained sales bonus	KRI	Acct Activity (Open/Close/Fund)				x	x	x		
35	Employee Misrepresentation to Bank	Misrepresentation of incentives / fee waivers	"% of customers receiving referral incentives, amount spent for referral incentives, i.e. ""Refer a friend to our services and receive $500"""	KPI	Sales Incentives Program				x	x	x		
36	Employee Misrepresentation to Bank	Misrepresentation of incentives / fee waivers	% of fee waivers applied each month by employee	KPI	Acct Activity (Open/Close/Fund)					x	x		
37	Employee Misrepresentation to Bank	Misrepresentation of incentives / fee waivers	# of customers who have a fee refund within the first 13 months overall/per colleague	KPI	Acct Activity (Open/Close/Fund)				x	x	x		
38	High Pressure Environment for Employees	ALL	# of whistleblower cases that remain unresolved	KRI	Employee Complaints			x	x	x			
39	High Pressure Environment for Employees	Employee complaints	% and/or # of employee complaints related to sales targets/ pressure	KRI	Employee Complaints			x	x	x			
40	High Pressure Environment for Employees	Employee complaints	% of voluntary employee separation due to management misconduct	KRI	Employee Separation			x	x	x			
41	High Pressure Environment for Employees	Employee complaints	Rate of employee dis-satisfaction	KRI	Employee Feedback				x	x			
42	High Pressure Environment for Employees	Incentive / Compensation Manipulation	# of whistleblower complaints related to gaming of incentive plans	KRI	Employee Complaints			x	x	x			
43	High Pressure Environment for Employees	Incentive / Compensation Manipulation	% of employees exceeding sales targets by 10%	KRI	Sales Incentives Program			x		x	x		
44	High Pressure Environment for Employees	Sales Pressure	"# of account applications that were declined/failed during account opening process, including timing of account application start date and incentive plan timing "	KPI	Acct Activity (Open/Close/Fund)				x	x	x		
45	High Pressure Environment for Employees	Sales Pressure	Total product sales volumes within 3 months of marketing campaign in relation to predicted amounts (above or below predicted amounts)	KPI	Acct Activity (Open/Close/Fund)				x		x		
46	Inappropriate Sales Tactics 	Aggressive Sales Tactics	"% of sales penetration (by products and services such as paperless statements) with sensitive classes (such as customers with limited credit options, elderly, service members)"	KPI	Acct Activity (Open/Close/Fund)				x	x			
47	Inappropriate Sales Tactics 	Aggressive Sales Tactics	% or # cross-sales made to customers with multiple existing products (illogical sales) by region or branch	KPI	Acct Activity (Open/Close/Fund)				x	x			
48	Inappropriate Sales Tactics 	Product Manipulation	# of accounts open for customers who do not qualify	KRI	Acct Activity (Open/Close/Fund)					x	x		
49	Inappropriate Sales Tactics 	Product Manipulation	# of accounts sold through unnecessary bundling of products and unusual product mix	KRI	Acct Activity (Open/Close/Fund)					x	x		
50	Inappropriate Sales Tactics 	Product Manipulation	# of accounts with steady increasing debt while making minimum payments	KRI	Acct Activity (Open/Close/Fund)			x	x	x			
51	Inappropriate Sales Tactics 	Product Manipulation	# or % of customers identified to be high risk in relation to total accounts opened during sales incentive program	KRI	Investigations				x	x			
52	Inappropriate Sales Tactics 	Product Manipulation	"Mismatch of customer's profile, based on peer analytics. Profile does not seem to align with the product"	KRI	Acct Activity (Open/Close/Fund)					x	x		
53	Inappropriate Sales Tactics 	Product Manipulation	"# of customers who received a credit card through cross selling, who would not have qualified through an invitation-to-apply process"	KRI	Acct Activity (Open/Close/Fund)					x	x		
54	Inappropriate Sales Tactics 	Product Manipulation	# of customers who were full balance payers for consecutive months and then switched to minimum payers	KPI	Acct Activity (Open/Close/Fund)			x		x	x		
55	Inappropriate Sales Tactics 	Product Manipulation	# of lower quality accounts (Rolling Funding Rate metric) and the rate of sales practice misconduct	KPI	Investigations			x	x	x	x		
57	Inappropriate Sales Tactics 	Product Manipulation	"% or # of sales practice related customer complaints about specific products, or employees"	KPI	Customer Complaints				x	x	x		
58	Inappropriate Sales Tactics 	Product Manipulation	"Product Sales volumes, made to intended or typical age range within target market, exceeds predicted volumes"	KPI	Acct Activity (Open/Close/Fund)					x	x		
59	Inappropriate Sales Tactics 	Product Manipulation	Review transactions to identify # of products that have not been activated after 30/ 90 days	KPI	Acct Activity (Open/Close/Fund)					x	x		
60	Inappropriate Sales Tactics 	Product Manipulation	# of products with high probabilty of sales practices risk	KRI	Investigations				X	x	x		
61	Inappropriate Sales Tactics 	Product Manipulation	Total # of mismatches of marketing information with product attributes	KRI	Investigations				X	X			
62	Inappropriate Sales Tactics 	Product Manipulation 	# of accounts having monthly repayment amounts as high percentage of customer disposable income	KRI	Acct Activity (Open/Close/Fund)			x	x	x			
63	Inappropriate Sales Tactics 	Product Manipulation 	# of customers who were previously active on cards but no longer use it	KPI	Acct Activity (Open/Close/Fund)					x	x		
65	Unauthorized Activity	"Funding Manipulation / 
Simulated Funding"	# and/or % of accounts that do not meet the minimum balance requirements within defined time period	KPI	Acct Activity (Open/Close/Fund)				x	x			
66	Unauthorized Activity	"Funding Manipulation / 
Simulated Funding"	# of customers funding accounts in a cadence and withdraw the fund	KPI	Acct Activity (Open/Close/Fund)			x	x	x			
67	Unauthorized Activity	"Funding Manipulation / 
Simulated Funding"	"% of accounts with excessive or unusual balance transfers, including transfers from accounts other than those of the customer"	KRI	Acct Activity (Open/Close/Fund)				x	x	x		
68	Unauthorized Activity	"Funding Manipulation / 
Simulated Funding"	% of new accounts that have made only minimum payments for the first 6 months	KPI	Acct Activity (Open/Close/Fund)				x	x	x		
69	Unauthorized Activity	"Funding Manipulation / 
Simulated Funding"	# of associated sales person receiving sales bonus after each funding activity	KPI	Sales Incentives Program				x	x	x		
70	Unauthorized Activity	"Funding Manipulation / 
Simulated Funding"	% of accounts opened that only meet the minimum required funding amount	KRI	Acct Activity (Open/Close/Fund)				x	x	x		
71	Unauthorized Activity	"Funding Manipulation / 
Simulated Funding"	# of accounts that have high risk funding source	KRI	Acct Activity (Open/Close/Fund)				x	x	x		
72	Unauthorized Activity	Insufficient Customer Consent	# of accounts down graded when employee receives credit	KRI	Acct Activity (Open/Close/Fund)			x	x	x	x		
73	Unauthorized Activity	Insufficient Customer Consent	# of  accounts with employee activity after business hours of operation by branch / region	KRI	Acct Activity (Open/Close/Fund)					x	x		
74	Unauthorized Activity	Insufficient Customer Consent	# of accounts opened with no customer acknowledgement	KRI	Acct Activity (Open/Close/Fund)				x	x	x		
75	Unauthorized Activity	Insufficient Customer Consent	# of customers who default within first 3 / 6 / 9 months overall	KPI	Acct Activity (Open/Close/Fund)				x	x	x		
76	Unauthorized Activity	Insufficient Customer Consent	"# of accounts that have been funded and funds transferred within 30 / 90 days of opening by region, branch, employee and/or product"	KRI	Acct Activity (Open/Close/Fund)				x	x			
77	Unauthorized Activity	Insufficient Customer Consent	# of accounts opened after the date when credit is applied	KPI	Acct Activity (Open/Close/Fund)				x	x			
78	Unauthorized Activity	Insufficient Customer Consent	# of unauthorized credit inquiries	KRI	Acct Activity (Open/Close/Fund)								
79	Unauthorized Activity	Insufficient Customer Consent	# or % of accounts closed within 30/60/90 days of opening	KRI	Acct Activity (Open/Close/Fund)				x	x			
80	Unauthorized Activity	Insufficient Customer Consent	% of accounts closed without documented client consent (by LOB)	KRI	Acct Activity (Open/Close/Fund)				x	x	x		
81	Unauthorized Activity	Other	"Outliers in wire transfer amounts per account, A single wire transfer with high-value transaction amount "	KRI	Acct Activity (Open/Close/Fund)			x	x	x			
82	Unauthorized Activity	Unauthorized account opening and closing	"# of account opened spikes and is inconsistent with historical performance or market sentiment by employee, division, and/or branch"	KRI	Acct Activity (Open/Close/Fund)				x	x	x		
83	Unauthorized Activity	Unauthorized account opening and closing	# of duplicate accounts by branch / region	KPI	Investigations					x	x		
84	Unauthorized Activity	Unauthorized account opening and closing	# of accounts closed with no activity (not consistent with historical observation)	KPI	Acct Activity (Open/Close/Fund)					x	x		
85	Unauthorized Activity	Unauthorized account opening and closing	# of accounts associated with existing customers and timing of the openings	KPI	Acct Activity (Open/Close/Fund)					x	x		
86	Unauthorized Activity	Unauthorized account opening and closing	# of applications accessed / opened from unauthorized computers trying to access the system 	KRI	Acct Activity (Open/Close/Fund)					x	x		
87	Unauthorized Activity	Insufficient Customer Consent	Total records with potential issues related to customer consent	KPI	Customer Complaints								
88	Unauthorized Activity	Insufficient Customer Consent	Records escalated with issues related to customer consent 	KPI	Customer Complaints								
89	All	All	Total employees required to take Sales Practices related training	KPI	Employee Training								
90	Unauthorized Activity	Other	Employees non compliant with Sales Practices related training requirements	KRI	Employee Training								
91	High Pressure Environment for Employees	Employee Complaints	Total exit surveys conducted/completed	KPI	Employee Feedback								
93	All	All	# or % of employees who  elected sales practice related issues as a reason for leaving	KPI	Employee Feedback								
99	High Pressure Environment for Employees	Sales Pressure	"Total performance improvement plans (PIP) initiated
"	KPI	Sales Incentives Program								
100	High Pressure Environment for Employees	Sales Pressure	Employee performance improvement plans initiated related to not meeting sales goals	KPI	Sales Incentives Program								
101	High Pressure Environment for Employees	Sales Pressure	Employee comments regarding sales goals  being too aggressive	KPI	Employee Feedback							MS: I think this is a separate metric.Please feel free to combine if you think otherwise	
103	All	All	Sales Practice employee related complaints: Non- anonymous issues	KPI	Customer Complaints							MS: I think this is a separate metric.Please feel free to combine if you think otherwise	
104	All	All	Potential Sales Practice related non-anonymous substantiated issues with customer impact	KPI	Customer Complaints							MS: I think this is a separate metric.Please feel free to combine if you think otherwise	
105	All	All	Potential Sales Practice related non-anonymous substantiated issues with customer impact that were resolved	KPI	Customer Complaints							MS: I think this is a separate metric.Please feel free to combine if you think otherwise	
106	All	All	"Potential Sales Practice related non-anonymous substantiated issues with no customer impact
"	KPI	Employee Feedback							MS: I think this is a separate metric.Please feel free to combine if you think otherwise	
107	All	All	Potential Sales Practice related non-anonymous substantiated issues with no customer impact that were resolved	KPI	Employee Feedback							MS: I think this is a separate metric.Please feel free to combine if you think otherwise	
108	High Pressure Environment for Employees	Employee Complaints	Sales Practice employee related complaints: Whistleblower (anonymous) issues	KPI	Employee Feedback							MS: I think this is a separate metric.Please feel free to combine if you think otherwise	
109	All	All	"Potential Sales Practice related anonymous substantiated issues with customer impact
"	KPI	Employee Feedback							MS: I think this is a separate metric.Please feel free to combine if you think otherwise	
110	All	All	Potential Sales Practice related anonymous substantiated issues with customer impact that were resolved	KPI	Employee Feedback							MS: I think this is a separate metric.Please feel free to combine if you think otherwise	
111	All	All	"Potential Sales Practice related anonymous substantiated issues with no customer impact
"	KPI	Employee Feedback							MS: I think this is a separate metric.Please feel free to combine if you think otherwise	
112	All	All	Potential Sales Practice related anonymous substantiated issues with no customer impact that were resolved	KPI	Employee Feedback							MS: I think this is a separate metric.Please feel free to combine if you think otherwise	
113	High Pressure Environment for Employees	Sales Pressure	Total employees that have a variable incentive policy violation by severity	KRI	Sales Incentives Program								
114	High Pressure Environment for Employees	Employee Complaints	"Employees who received a pay adjustment based on
Sales Practice related issue/s"	KRI	Sales Incentives Program								
115	Unauthorized Activity	"Funding Manipulation / 
Simulated Funding"	# or % of accounts with zero balance	KPI	Acct Activity (Open/Close/Fund)								
118	All	All	Spike in number of dormant accounts with balance below the required minimum	KPI	Acct Activity (Open/Close/Fund)								
119	High Pressure Environment for Employees	Sales Pressure	# or % of sales by business unit	KPI	Sales Incentives Program								
120	Inappropriate Sales Tactics	Product Misrepresentation	# or % of employees who fail to provide the required disclosures	KPI	Customer Complaints								
123	Unauthorized Activity	Unauthorized account activity	# and/or % of accounts opened by employees under investigation	KRI	Acct Activity (Open/Close/Fund)								
124	Unauthorized Activity	Insufficient Customer Consent	# or % of records with issues related to verbal consent to pull credit for when a customer applies for a mortgage product	KPI	Customer Complaints								
125	Inappropriate Sales Tactics	Aggressive Sales Tactics	# or % of borrowers who felt that the loan did not close in a timely manner and/or did not get the expected rate	KPI	Customer Complaints								
126	All	All	"# and/or % customer complaints by topic, geography, and/or channel (i.e. call center, branch, social media)"	KPI	Customer Complaints								
127	All	All	# and/or % of customer complaints about third party experiences	KPI	Customer Complaints								
128	All	All	# or % pending issues from prior quarters that were resolved during the quarter	KRI	Investigations	Investigations	Investigations	Investigations	Investigations	Investigations	Investigations		
129	All	All	# and/or % of pending issues at end of quarter	KRI	Investigations	Investigations	Investigations	Investigations	Investigations	Investigations	Investigations		
131	High Pressure Environment for Employees	Incentive / Compensation Manipulation	Production volume and $ incentives paid out as a % of total $ payout per plan by product	KPI	Sales Incentives Program								
132	All	All	# and/or %  of third party contract breach and/or issues relating to sales practice misconduct	KRI	Customer Complaints								
133	Inappropriate Sales Tactics	Misrepresentation of Product to customer	Total # or % of mismatches of marketing information with product attributes.	KRI	Sales Incentives Program								
134	All	All	Total # of FHA (Federal Housing Administration) monthly submissions audited	KPI	Investigations								
139	Inappropriate Sales Tactics	Aggressive sales tactics	# or % of calling campaigns by status per division/region/branch for deposit and loan accounts	KPI	Sales Incentives Program								
140	Unauthorized Activity	Creation of unnecessary accounts	# or % of new accounts in tracking/ in grace/ out of grace per division/region	KPI	Acct Activity (Open/Close/Fund)								
141	All	All	# or % of loans with non-critical findings 	KPI	Customer Complaints								
142	High Pressure Environment for Employees	Incentive / Compensation Manipulation	"# or % of incentive compensation programs across time, by region or branch"	KPI	Sales Incentives Program								
143	High Pressure Environment for Employees	Employee Complaints	"# or % of employees with policy violations per level per quarter
X MDs, X Directors, X VPs, X AVPs, X Analysts, X Non-Officers"	KPI	Employee Feedback								
144	All	All	# or % of customers who felt that they were asked for the same document more than once	KPI	Customer Complaints								
145	Unauthorized Activity	Insufficient Customer Consent	# or % of borrowers who were not contacted before closing	KPI	Customer Complaints								
146	Unauthorized Activity	"Funding Manipulation / 
Simulated Funding"	"# or % of accounts with transactions less than $10 on account within 1, 2, & 3 months of account opening"	KPI	Acct Activity (Open/Close/Fund)								
148	All	All	"# and/or % of non disciplinary actions by type such as provided guidance/information, training, work discussion"	KPI	Employee Feedback								
149	Inappropriate Sales Tactics	Aggressive sales tactics	# and/ or $ of daily new accounts opened and funded by geography and across time (end of quarter vs beginning of quarter) per employee	KPI	Acct Activity (Open/Close/Fund)								
150	All	All	 # or % of Loans with FHA issues not remediated	KRI	Customer Complaints								
151	All	All	" # and/or % of loans having critical errors
"	KPI	Customer Complaints								
152	All	All	# of annuity rescinds	KPI	Employee Incentives								
153	All	All	# of responsive customer complaints related to Aggressive Sales	KRI	Bank-related Cust. Complaints								
154	All	All	# of responsive customer complaints related to Falsifying Customer Information	KRI	Bank-related Cust. Complaints								
155	All	All	# of responsive customer complaints related to Management Pressure	KRI	Bank-related Cust. Complaints								
156	All	All	# of responsive customer complaints related to Misrepresentation	KRI	Bank-related Cust. Complaints								
157	All	All	# of responsive customer complaints related to Process Manipulation	KRI	Bank-related Cust. Complaints								