Consumer compliance testing on every item, not a sample: each exception beside its evidence, its cause found, and every finding approved by a person
Every item tested, not 60, and every exception evidenced before the exam.
See one case, screen by screen ↓Consumer compliance testing is the second line's check that deposit and payment operations follow Regulations CC, E and DD: holds and their notices, error claims and their deadlines, disclosures and change-in-terms notices. Consumer Compliance Testing runs each test on every item the data allows, not a sample: agents read every notice and record, lay each exception beside its evidence and find the cause, and the analyst confirms while the Compliance Manager approves.
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Consumer compliance testing is how the second line proves that deposit and payment operations follow Regulations CC, E and DD: that a hold kept back only what the rule allows and came with a proper notice, that an error claim was credited and answered on time, that disclosures and change-in-terms notices went out. Today the compliance testing analyst draws a sample of about 60 items a script each quarter, asks for a population extract, opens each notice image beside its core record and types the result into a spreadsheet, or the bank pays an outside firm to do it.
A sample misses errors that cluster. At the sample bank, six whole-deposit holds at two branches were 6 in 1,512; a 60-item sample would most likely have missed all of them, and the error would have run another quarter. Population extracts can miss records quietly, findings arrive weeks after the quarter, causes are guessed, and a fix is validated by next quarter's sample. Meanwhile customers pay fees for funds the bank should have released.
Estimated split of the 31 business days the sample bank's Q2 2026 testing took to approved findings with sampling and an outside reviewer, and the about 9 the solution's design aims for.
Seven agents pull, test, re-test and explain every item; the analyst confirms and the Compliance Manager approves.
Tessaly Community Bank, 41 branches, placed 1,512 exception holds in Q3 2026. Test CC-07 checks every one of them. Here is what happens on Thursday, October 22, screen by screen, in the working solution.
Her Testing home shows Q3 2026: 9,012 items tested, every item in 10 of 14 scripts, 19 exceptions each with a workpaper, 469 re-tested by the Reviewer agent and 3 findings. 'Needs you' lists four items by due date, led by the CC-07 exceptions to confirm by Fri Oct 23. DD-01 cannot run: 43 disclosure images are missing.
Since yesterday: “Pattern agent found 3 overdraft fees, $102.00, charged while funds were held too long.”
The test reads as one plain sentence across the top. Under it, the result: 1,512 holds tested, all of them, and 9 exceptions. The Population agent reconciled the count to the core's daily hold report first (1,512 = 1,512). Five attribute tiles, each cited to Regulation CC, show where the failures sit: A2, only what the exception allows is held, 7; A4, what the notice states, 7.
“Every exception hold held only what the rule allows, and came with a notice giving the reason and when the funds will be available.”
She picks the first notice from the fanned stack. Adaeze Brennan deposited a $9,800.00 check from Halvorsen Mutual Insurance Co. at Hollins Ferry on Fri Aug 14. The core held all of it until Tue Aug 25, and the notice, form TCB-HN-2019, says 'Amount delayed: entire deposit' and quotes the retired $5,525 threshold. Under the record, the arithmetic: only $3,075.00 could be held longer; $275.00 was due Mon Aug 17 and $6,450.00 Tue Aug 18.
Testing agent: “The core held all of it until Tue Aug 25; only the $3,075.00 above $6,725 could be held beyond the normal schedule.”
Six of the nine are the same error: every large-deposit hold at Hollins Ferry and Quarry Hill held the whole deposit, because their teller platforms still print form TCB-HN-2019, retired on Jul 1, 2025. The other 39 branches held only the excess on all 214 of theirs. 'Show the 6' highlights them in the stack and dims the other three.
The Pattern agent proposes causes; the Compliance Manager approves them.
The Reviewer agent re-tested the 9 exceptions and 76 passes on CC-07 without seeing the first answer, and agrees on all 85. Across the quarter it re-tested 469 items and disagrees on one: Reg E claim RE-26-08817, $486.20, passed at business day 9 from the day it was keyed. The customer first called on Thu Aug 27, so with Labor Day skipped, Mon Sep 14 is business day 11. Marisol decides.
The Reviewer agent never sees the first answer and never settles a disagreement.
The Pattern agent reads the two branches' hold files back to Jul 1, 2025 and finds 21 more holds on the whole deposit: 27 customers in all, each with $6,725.00 held up to 5 business days too long. Three paid a $34.00 overdraft fee while their funds were held. The Workpaper agent drafts finding F-26-031 as criteria, condition, cause, effect and recommendation, each cited.
Recommendation: “Point both branches to TCB-HN-2025 … refund the $102.00 in fees … re-test every large-deposit hold at both branches in November before the issue closes.”
She confirmed EX-7 to EX-9 on Wednesday as isolated errors, reported to their branch managers with no finding. Now she confirms the six with the same cause in one step, each keeping its own workpaper, and sends F-26-031 to Graham Okonjo with 9 workpapers and a note proposing High severity because customers paid fees.
“Prepared by you; Graham Okonjo approves. You cannot approve your own finding.”
In Approvals he sees the finding, its 6 workpapers, the look-back on 21 holds, the Reviewer agent agreeing on 85 of 85, and no cleared exceptions. He picks the reason AP-1, finding and root cause agreed, adds a note and approves. Viewed as the analyst, the same approval is locked; viewed as the Internal Auditor, it is read only.
His note: “Agree High. Ask Renata to check every teller platform's form settings, not only the two.”
Issue ISS-26-114 opens for Renata Szabo, Deposit Operations Supervisor, High, due Fri Nov 20, 2026. Its actions: point both branches to TCB-HN-2025, check the form settings on every teller platform, refund $102.00 to 3 customers with a maker and a checker, a refresher for 9 tellers, and a validation re-test on November holds. Only the Compliance Manager can close it, after the re-test.
Refunds: Renata Szabo signs as maker, Ines Marchetti as checker, before any money moves.
The audit trail holds every agent and person: when, who, what, why with its reason code, the evidence and the item. The top rows show the Issue agent opening ISS-26-114, Graham approving F-26-031 under AP-1, Marisol sending the finding and confirming six exceptions in one step, and the Pattern agent's look-back. One click builds the examiner pack, with account numbers masked.
The same test, seen by the people who run it, approve it, fix what it found and audit it: what their quarter looked like, and what it looks like now.
Seven agents pull, test, re-test and explain every item; the analyst confirms and the Compliance Manager approves.
Pulls each script's whole population from the systems of record and reconciles it to an independent count: the daily hold report, the claim register, the general ledger fee line.
Turns a test written as one plain sentence into attributes cited to the regulation, and dry-runs any change on last quarter's items.
Reads every notice, letter and disclosure image, compares it with the core record and decides each attribute, citing the evidence for every fail.
Re-tests every exception and 5% of passes at random, blind, on a second model family.
Groups exceptions by cause, checks the cause against the rest of the bank, runs the look-back and finds customer harm such as fees charged while funds were held.
Writes a workpaper for every exception and drafts the finding as criteria, condition, cause, effect and recommendation.
Opens the issue for the business owner, tracks due dates and escalations, drafts refunds and re-tests the fix before closure.
Confirms; the Compliance Manager approves. The agents propose; a named person decides.
Ask in plain words about a hold, a branch, a rule change or the exam. Every answer cites the rule and the record, and opens the screen it talks about.
Why is the Brennan hold an exception?
Adaeze Brennan's $9,800.00 check on Fri Aug 14 was her only deposit that day, so the large-deposit exception covered only the $3,075.00 above $6,725. The core held all $9,800.00 until Tue Aug 25, and the notice says "entire deposit". $275.00 was due Mon Aug 17 and $6,450.00 Tue Aug 18.
Which branches still use the old hold notice?
Hollins Ferry and Quarry Hill. Their teller platforms still print form TCB-HN-2019, retired on Jul 1, 2025. All 6 of their Q3 large-deposit holds held the whole deposit, while the 214 at the other 39 branches held only the excess. The look-back found 21 more since Jul 1, 2025.
What changed in Regulation CC on July 1, 2025?
The inflation adjustment raised the next-day amount from $225 to $275, and the new-account, large-deposit and repeated-overdraft thresholds from $5,525 to $6,725. Script CC-07 has tested the new amounts since v3.
Build the examiner pack for Q3 testing
The pack holds the program and policy, the 14 scripts with their versions, 10 reconciled populations, every result, the workpapers, 469 blind re-tests, the findings with their approvals, the issues and the whole trail, with account numbers masked.
13 screens from the working solution, on its sample data. Pick one to see it large.
The rules every test runs by are settings, versioned with who, when and why; testing rules and scripts also need the Compliance Manager's approval.
| Setting | Default | Choose from |
|---|---|---|
| Reviewer agent re-test | Every exception, plus 5% of passes | 5% · 10% · 3% of passes |
| Confidence floor | 0.95 | 0.95 · 0.97 · 0.90; below it, an item goes to a person |
| Confirm exceptions within | 10 business days of the run | 10 · 5 business days |
| Approve findings within | 15 business days of sending | 15 · 10 business days |
| Issue due dates by severity | High 30 days, Moderate 60, Low 90 | On, locked |
| Escalate overdue issues | To the Chief Compliance Officer, the next business day | On, locked |
| Override reason codes | Required on cleared exceptions and on approvals | On, locked |
| Workpaper retention | 7 years | 7 · 10 years; Regulations CC, E and DD require two |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate: the split of a quarter's business days · “typical” = published figures (St. Louis Fed, “Scale Matters: Community Banks and Compliance Costs,” Regional Economist, July 2016: 2.9% to 8.7% of noninterest expense). Rules: Regulation CC, 12 CFR 229.10, 229.12 and 229.13, with the thresholds in force from July 1, 2025 (89 FR 43737) · Regulation E, 12 CFR 1005.11 · Regulation DD, 12 CFR 1030 · FDIC Consumer Compliance Examination Manual II-3 (ecfr.gov, federalregister.gov, fdic.gov). Tessaly Community Bank, Halvorsen Mutual Insurance Co., and the people, branches, customers and accounts named on this page are fictional: characters and sample data in the working solution.
Consumer compliance testing is the second line's check that deposit and payment operations follow Regulations CC, E and DD: holds and their notices, error claims and their deadlines, disclosures and change-in-terms notices. Consumer Compliance Testing runs each test on every item the data allows, not a sample: agents read every notice and record, lay each exception beside its evidence and find the cause, and the analyst confirms while the Compliance Manager approves.
The test is one sentence with five attributes cited to Regulation CC: the exception fits the deposit, only what it allows is held, the notice was given on time, it states the account, date, amount, reason and availability, and funds were available within a reasonable period. The Testing agent reads every notice image beside the core's hold record and shows the arithmetic of what could be held.
Since July 1, 2025 the large-deposit threshold is $6,725 a banking day, up from $5,525, and the next-day amount is $275, up from $225. Only the part of a day's deposits above $6,725 may be held beyond the normal schedule. In the working solution's sample quarter, two branches still printed a notice form with the old threshold.
It finds what a sample misses when errors cluster. On the sample data, six whole-deposit holds at two branches were 6 in 1,512; a 60-item sample would most likely have missed all of them. One script in 14 still samples, a statement test of 40 items, because the statement images allow no more.
Yes. A script tests that every error claim got provisional credit or a result within 10 business days, and a result within 45 or 90 days; another tests the notices. On the sample data, the Reviewer agent counted from the customer's first call rather than the day the claim was keyed, with Labor Day skipped, and found a credit on business day 11.
Yes. The agents propose and cite; the analyst confirms or clears each exception with a reason code, the Compliance Manager approves every finding, root cause, script change and issue closure, and refunds are signed by a maker and a checker. The person who prepares a finding can never approve it, and below 0.95 confidence an item goes to a person.
A change to a test's sentence is compiled into cited attributes, dry-run on last quarter's items, and approved by the Compliance Manager before it runs. Every version is kept with who changed it and why, and a new model or prompt version re-runs last quarter first.
The Agentic Solution Engine builds and deploys it from your requirements and documents: your testing program, your scripts and a quarter of past populations and notices. It goes live once every quality gate has passed, and we walk you through it on your own holds and claims first.
Every affected customer found and paid, and every dollar traced to its end.
1-min demoUDAAP Risk AssessmentMisleading claims, hidden fees and hard exits fixed before launch, not refunded after.
1-min demoConsumer Duty Outcomes MonitoringEvery board report sentence tied to its data, and every weak point challenged first.
1-min demoWe'll run Consumer Compliance Testing on a quarter of your own exception holds, Reg E claims and notices.