# 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