Purpose
Ensure regulator communications are professional, authorized, documented, secure and retrievable. This procedure implements the Communication Framework (section 4) and the Documentation and Audit Trail requirements (section 8.5) of the approved Regulatory Reporting & Communication Manual.
Communication Framework (Section 4)
Tone
All communication with regulatory authorities must be professional, transparent, factual, and timely. Submissions or responses must:
- Present information objectively, without speculation or unnecessary interpretation.
- Avoid jargon and use clear, precise language that regulators can easily understand.
- Reflect transparency by disclosing all relevant facts, even if adverse, while highlighting corrective measures already taken.
- Be delivered within regulatory deadlines to demonstrate reliability and respect for supervisory processes.
Format
The preferred format for communication with regulators is written correspondence, unless otherwise directed by the authority. This includes:
- Formal letters for official submissions, signed by authorized representatives.
- Emails for routine updates, clarifications, or requests for information, ensuring professional tone and formatting.
- Regulatory portals where mandatory filings (e.g., FIU reports, tax submissions, CBCS templates) must be uploaded in the required format.
- In-person or telephone conversations should be minimized, and when they occur, they must be documented in writing immediately afterward.
Recordkeeping
All regulatory communications, filings, decisions, drafts, supporting evidence, escalation records, and follow-up actions must be retained in a secure and retrievable manner.
For AML/CFT/CPF and sanctions matters, the record must include, where applicable:
- the alert or trigger;
- internal classification;
- review notes and rationale;
- the basis for false-positive closure, where relevant;
- the status and outcome of escalation;
- any restrictive measures taken;
- UTR filing details, where applicable; and
- any CBCS notification or reporting record, where applicable.
Documentation and Audit Trail (Section 8.5)
All reporting and communication activities are supported by verifiable documentation, including submission records, internal reviews, and correspondence evidence. A centralized Regulatory Communication Log records:
- Date and type of communication
- Counterparty regulator
- Subject and summary
- Responsible preparer and approver
- Follow-up or corrective action (if applicable)
All records are retained for at least five (5) years, or longer when required by regulators or ongoing reviews.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Log communication or request | Log each communication or request in the centralized Regulatory Communication Log with: date and type of communication, counterparty regulator, subject and summary, responsible preparer and approver, follow-up or corrective action (if applicable), and confidentiality classification. | Regulatory Communication Log entry |
| 2 | Use clear and factual language | Present information objectively without speculation; avoid jargon; use clear and precise language that regulators can easily understand; disclose relevant adverse facts and corrective measures. | Final communication draft |
| 3 | Use written correspondence | Use formal letters signed by authorized representatives, emails, or regulatory portals as the preferred format, unless otherwise directed by the authority. | Written correspondence or portal submission |
| 4 | Document verbal communications | Document telephone or in-person communication immediately afterward — such conversations should be minimized and must be documented in writing immediately after they occur. | Written documentation of verbal communications |
| 5 | Coordinate responses and obtain approval | Coordinate complete and accurate responses and obtain approval before release from the authorized representative. | Approved response record |
| 6 | Preserve records securely | Preserve drafts, evidence, decisions, correspondence and follow-up in a secure and retrievable manner. | Secure record repository |
| 7 | Restrict AML/sanctions records | For AML/CFT/CPF and sanctions matters, restrict records and prevent unauthorized disclosure (tipping-off prohibition). The record must include, where applicable: the alert or trigger, internal classification, review notes and rationale, basis for false-positive closure, status and outcome of escalation, restrictive measures taken, UTR filing details, and any CBCS notification or reporting record. | Restricted-access AML/sanctions case file |
| 8 | Retain records | Retain records for at least five (5) years, or longer when required by regulators or ongoing reviews. | Retention evidence and retention schedule |
Records
- Centralized Regulatory Communication Log (date, type, counterparty regulator, subject, summary, preparer, approver, follow-up)
- Written correspondence and portal submissions
- Meeting and call documentation (written immediately afterward)
- AML/CFT/CPF and sanctions case records (with all required fields per section 4.4)
- Drafts, evidence, decisions, and follow-up
Relationships
- Policy: POL-REG-001 Regulatory Reporting and Communication Manual
- Process: PRC-RSA-001 Resilience Systems and Assurance
- Control: CTRL-REG-006 Ensure Regulatory Communications and Records Are Traceable
History
- 2026-07-26: Created from sections 4 and 8.5 of the approved REG Manual.
- 2026-07-28: Enriched with full Communication Framework (tone, format, recordkeeping), AML/CFT/CPF record fields, and centralized Regulatory Communication Log structure from PDF sections 4 and 8.5.