Risk_Taxonomy_ID Risk_Taxonomy_Level_1 Risk_Taxonomy_Level_2 Metric Signal_Source 1 Unauthorized Activity Unauthorized account opening and closing # of account opened spikes and is inconsistent with historical performance or market sentiment Acct Activity (Open/Close/Fund) 3 Unauthorized Activity Unauthorized account activity # of duplicate accounts by branch / region Investigations 4 Unauthorized Activity Unauthorized account opening and closing # of accounts closed with no activity (not consistent with historical observation) / Spike in number of dormant accounts with balance below a threshold Acct Activity (Open/Close/Fund) 5 Unauthorized Activity Insufficient Customer Consent # of accounts down graded when employee receives credit Acct Activity (Open/Close/Fund) 6 Unauthorized Activity Unauthorized account activity # of accounts with employee activity after business hours of operation by branch / region Acct Activity (Open/Close/Fund) 7 Unauthorized Activity Insufficient Customer Consent # of accounts opened with no customer acknowledgement Acct Activity (Open/Close/Fund) 8 Unauthorized Activity "Funding Manipulation / Simulated Funding" # of accounts that do not meet the funding requirements within defined time period Acct Activity (Open/Close/Fund) 10 Unauthorized Activity Unauthorized account activity # of applications accessed / opened from unauthorized computers trying to access the system Acct Activity (Open/Close/Fund) 12 Unauthorized Activity "Funding Manipulation / Simulated Funding" # of customers funding accounts in a cadence and withdraw the fund Acct Activity (Open/Close/Fund) 13 Unauthorized Activity Insufficient Customer Consent # of customers who default within first 3 / 6 / 9 months overall Acct Activity (Open/Close/Fund) 15 Unauthorized Activity Insufficient Customer Consent # of accounts that have been funded and funds transferred within 30 / 90 days of opening Acct Activity (Open/Close/Fund) 17 Unauthorized Activity Insufficient Customer Consent # of accounts opened after the date when credit is applied Acct Activity (Open/Close/Fund) 19 Unauthorized Activity Insufficient Customer Consent # of accounts open for customers who do not qualify (# of unauthorized credit inquiries) Acct Activity (Open/Close/Fund) 20 Unauthorized Activity Insufficient Customer Consent # or % of accounts closed within 30/60/90 days of opening Acct Activity (Open/Close/Fund) 21 ALL Insufficient Customer Consent "# or % of allegations of employee involvement in sales practice misconduct (by region, product etc.)" Investigations 22 Unauthorized Activity Insufficient Customer Consent % of accounts closed without documented client consent (by LOB) Acct Activity (Open/Close/Fund) 23 Unauthorized Activity "Funding Manipulation / Simulated Funding" "% of accounts with excessive or unusual balance transfers, including transfers from accounts other than those of the customer" Acct Activity (Open/Close/Fund) 24 Unauthorized Activity False Entries / CIP (Customer Idenfitication Program) Violations "% of CIP violations (lack of entries for name, DOB, address, identification number at minimum) in relation to the # of accounts opened" Acct Activity (Open/Close/Fund) 25 ALL ALL % of employee turnovers by branch or region Employee Separation 26 ALL Other # of sales practices trainings by delinquency (30-60-90 days) Employee Training 28 Employee Misrepresentation "Funding Manipulation / Simulated Funding" % of new accounts that have made only minimum payments for the first 6 months Acct Activity (Open/Close/Fund) 29 Employee Misrepresentation Falsifying customer information Age of customers when opening a credit card (to verify if those under 21 provided signature when opening account) Investigations 31 ALL Other "Investigation by status (No action, open, pending, resulted in action)" Investigations 32 Employee Misrepresentation Targeting Inappropriate Customer "# of account applications that were started and not completed, including timing of account application start date and incentive plan timing" Acct Activity (Open/Close/Fund) 33 Inappropriate Sales Tactics Targeting Inappropriate Customer # of accounts having monthly repayment amounts as high percentage of customer disposable income Acct Activity (Open/Close/Fund) 34 Inappropriate Sales Tactics Product Manipulation # of accounts sold through unnecessary bundling of products and unusual product mix Acct Activity (Open/Close/Fund) 35 Employee Misrepresentation Targeting Inappropriate Customer # of accounts with steady increasing debt while making minimum payments Acct Activity (Open/Close/Fund) 36 All Misinformation of product # of customer complaints that remain unresolved related to product dissatisfaction Customer Complaints 37 Inappropriate Sales Tactics Targeting Inappropriate Customer # of customers identified to be high risk in relation to total accounts opened during sales incentive program Investigations 38 Inappropriate Sales Tactics Misrepresentation of Product to customer "Mismatch of customer's profile, based on peer analytics. Profile does not seem to align with the product" Acct Activity (Open/Close/Fund) 39 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" Acct Activity (Open/Close/Fund) 40 Employee Misrepresentation Targeting Inappropriate Customer # of customers who were full balance payers for consecutive months and then switched to minimum payers Acct Activity (Open/Close/Fund) 41 Inappropriate Sales Tactics Misinformation of product # of lower quality accounts (Rolling Funding Rate metric) and the rate of sales practice misconduct Investigations 42 Inappropriate Sales Tactics Targeting Inappropriate Customer % of sales of new products to customers over age 65 / vulnerable classes Acct Activity (Open/Close/Fund) 43 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)" Acct Activity (Open/Close/Fund) 44 Inappropriate Sales Tactics Aggressive Sales Tactics % or # cross-sales made to customers with multiple existing products (illogical sales) by region or branch Acct Activity (Open/Close/Fund) 45 Inappropriate Sales Tactics Misinformation of product "% or # of customer complaints related to specific products, or employees" Customer Complaints 46 Inappropriate Sales Tactics Product Manipulation "Product Sales volumes, made to intended or typical age range within target market, exceeds predicted volumes" Acct Activity (Open/Close/Fund) 47 Employee Misrepresentation Product Manipulation Review transactions to identify # of products that have not been activated after 30/ 90 days Acct Activity (Open/Close/Fund) 48 Inappropriate Sales Tactics Misinformation of product Total product sales volumes within 3 months of marketing campaign in relation to predicted amounts (above or below predicted amounts) Acct Activity (Open/Close/Fund) 49 Inappropriate Sales Tactics Product Manipulation # of products with high probabilty of sales practices risk Investigations 50 Inappropriate Sales Tactics Misrepresentation of Product to customer Total # of mismatches of marketing information with product attributes Investigations 51 Employee Misrepresentation Creation of Unnecessary Accounts "# of account applications that were declined/failed during account opening process, including timing of account application start date and incentive plan timing " Acct Activity (Open/Close/Fund) 53 Unauthorized Activity Incentive / Compensation Manipulation # of associated sales person receiving sales bonus after each funding activity Sales and Employee Incentive 54 Unauthorized Activity Creation of Unnecessary Accounts # of accounts associated with existing customers and timing of the openings Acct Activity (Open/Close/Fund) 56 Unauthorized Activity Incentive / Compensation Manipulation # of accounts opened through a sales practice incentive program Sales and Employee Incentive 57 Unauthorized Activity Incentive / Compensation Manipulation "# 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" Sales and Employee Incentive 58 Inappropriate Sales Tactics Sales Pressure / Incentive / Compensation Manipulation # of accounts/products sold with a disproportionately high number of accepts within the first and last few days of the incentive period Acct Activity (Open/Close/Fund) 59 ALL Sales pressure "# of bankers who received coaching, counseling, reprimands, warning, and/or written warning for S.P misconducts" Investigations 60 Unauthorized Activity Incentive / Compensation Manipulation # of credit cards product fee refunds - rate of refunds per employee each month Acct Activity (Open/Close/Fund) 61 Unauthorized Activity Incentive / Compensation Manipulation # of credit Cards product interest refunds - rate of refunds per employee each month Acct Activity (Open/Close/Fund) 64 High Pressure Environment for Employees Incentive / Compensation Manipulation # of whistleblower complaints related to gaming of incentive plans Employee Complaints 65 Unauthorized Activity Incentive / Compensation Manipulation % accounts closed after opened and funded account or after the associated sales person obtained sales bonus Acct Activity (Open/Close/Fund) 66 Unauthorized Activity Incentive / Compensation Manipulation % accounts dormant after opened and funded account or after the associated sales person obtained sales bonus Acct Activity (Open/Close/Fund) 67 High Pressure Environment for Employees Employee complaints % and/or # of employee complaints related to sales targets/ pressure Employee Complaints 68 Unauthorized Activity Incentive / Compensation Manipulation % of accounts opened that only meet the minimum required funding amount Acct Activity (Open/Close/Fund) 69 Inappropriate Sales Tactics Referrals pressure "% of customers receiving referral incentives, amount spent for referral incentives, i.e. ""Refer a friend to our services and receive $500""" Sales and Employee Incentive 71 High Pressure Environment for Employees Incentive / Compensation Manipulation % of employees exceeding sales targets by 10% Sales and Employee Incentive 72 ALL ALL % of involuntary employee separation due to S.P. related employee misconduct Employee Separation 74 High Pressure Environment for Employees Employee complaints % of voluntary employee separation due to management misconduct Employee Separation 75 ALL Sales pressure "% or # of sales targets that are barely but consistently met and variations across regions, business units and individuals" Sales and Employee Incentive 76 ALL Sales Pressure / Incentive / Compensation Manipulation "Customer feedback trends by channel (i.e. call center, branch, social media)" Customer Complaints 78 High Pressure Environment for Employees Employee complaints Rate of employee dis-satisfaction Employee Feedback 80 Unauthorized Activity Creation of Unnecessary Accounts # of customers who were previously active on cards but no longer use it Acct Activity (Open/Close/Fund) 83 Employee Misrepresentation Incentive / Compensation Manipulation % of fee waivers applied each month by employee Acct Activity (Open/Close/Fund) 84 Employee Misrepresentation 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 Acct Activity (Open/Close/Fund) 86 Unauthorized Activity Falsification of accounts # of accounts opened and closed by the same banker Acct Activity (Open/Close/Fund) 88 Employee Misrepresentation Falsification of accounts "# of accounts that failed Experian, but passed the out of pocket questions to open the account and banker associated with the account opening " Acct Activity (Open/Close/Fund) 89 Employee Misrepresentation Falsification of accounts # of accounts that have high risk funding source Acct Activity (Open/Close/Fund) 90 Employee Misrepresentation Falsification of bank records # of accounts that list branch or employee addresses as mailing address during application process Acct Activity (Open/Close/Fund) 91 Employee Misrepresentation Falsification of bank records "# of accounts that list incorrect email addresses during application process (branch, employee or other invalid email address not match customer profile)" Acct Activity (Open/Close/Fund) 92 Employee Misrepresentation Falsification of bank records # of accounts with incomplete account information Acct Activity (Open/Close/Fund) 93 Employee Misrepresentation Falsification of accounts "% approval rates, look for outliers" Sales and Employee Incentive 94 Employee Misrepresentation Falsification of accounts # of colleagues with non-typical spread of loan type more longer term over shorter term loans compared to average Sales and Employee Incentive 95 Employee Misrepresentation Misrepresentation of sales / quotas # of customers still on variable rollover product 6/12 months after rate expires Acct Activity (Open/Close/Fund) 96 Unauthorized Activity Incentive Manipulation # of customers who have a fee refund within the first 13 months overall/per colleague Acct Activity (Open/Close/Fund) 97 Employee Misrepresentation Falsification of bank records # of follow-ups documented in relation to # of customer complaints Customer Complaints 98 Employee Misrepresentation Falsification of accounts "# of transactions with a high accept rate, but low Call Handling Time" Acct Activity (Open/Close/Fund) 99 Employee Misrepresentation Incentive Manipulation "# of transactions with a high offer rate, but low conversion rate" Acct Activity (Open/Close/Fund) 100 Employee Misrepresentation Falsification of bank records # of whistleblower cases that remain unresolved Employee Complaints 101 Employee Misrepresentation Falsification of bank records "% of accounts with change in profile information (email, addrress, pin etc. )" Acct Activity (Open/Close/Fund) 102 Employee Misrepresentation Falsification of bank records % of accounts opened with nothing scanned in for NAO (National Audit Office?) documents and the name of banker associated Acct Activity (Open/Close/Fund) 103 Employee Misrepresentation Falsification of bank records % of offer accepts that occurred on a different date from the call date Acct Activity (Open/Close/Fund) 104 Unauthorized Activity Other "Outliers in wire transfer amounts per account, A single wire transfer with high-value transaction amount " Acct Activity (Open/Close/Fund) 105 All All Customer feedback by risk taxonomy topic Customer Complaints