Trust & Custody Ops Redesign
Regulatory Turnaround: Trust & Custody Operations
A global custody bank facing escalating MRAs from the Federal Reserve and OCC engaged Laksh Vaswani to redesign its Trust & Custody operations from the ground up. The institution had accumulated years of control gaps — manual reconciliation processes, undefined ownership across business lines, and a compliance framework that had outpaced the bank’s operational maturity.
The Challenge
The bank’s Trust & Custody division managed $2T+ in assets under custody but operated on legacy processes with significant regulatory exposure. Three consecutive examination cycles had surfaced repeat findings. The board mandated a full remediation programme within 18 months.
The Approach
Laksh embedded directly within the senior leadership team, conducting a rapid diagnostic across all three lines of defence. Within 60 days, a comprehensive Target Operating Model (TOM) was delivered — redefining roles, escalation paths, and control ownership at every layer of the organisation.
- Full 3LOD architecture redesign with clear RACI across front office, risk, and audit
- MRA-by-MRA corrective action plans with examiner-ready evidence packages
- Technology gap assessment and prioritised remediation roadmap
- Regulator communication strategy and examination prep for FRB and OCC
- Embedded governance framework with board-level reporting cadence
The Outcome
All open MRAs closed within the examination cycle — zero repeat findings. The OCC examiner noted the programme as a model for peer institutions. Operational efficiency improved 35% through process redesign, and the division passed its next scheduled examination with no new matters raised.
Result: Full regulatory close-out | Zero repeat MRAs | 35% operational efficiency gain | Examiner commendation