Success Stories
Case Study – Trust & Custody Ops Redesign | Laksh Vaswani
Learn how Laksh Vaswani led a large-scale redesign of trust and custody operations, resolving audit gaps, aligning with OCC 12 CFR 9, and modernizing a legacy platform.
Legacy Systems, OCC Gaps — and a Mandate to Modernize
How Laksh led a transformation of trust and custody operations, aligned fiduciary obligations with regulatory expectations, and restructured controls without disrupting business flow.
The Challenge
A Decade of Technical Debt, Audit Gaps, and OCC Exposure
The organization had inherited legacy trust systems that lacked control visibility, documentation traceability, and regulatory alignment. With an OCC exam scheduled and fiduciary operations under scrutiny, the business needed a redesign — fast.
Internal Audit had 3 years of outstanding findings. Processes were dependent on outdated tech, manual handoffs, and untrained staff. There was no clear RCSA, no fiduciary audit trail, and no scalable control model.
Laksh’s Role
Leading a Non-Disruptive Overhaul of a Mission-Critical Platform
Key Actions Taken:
- Partnered with business heads and control functions to inventory and assess all trust/custody processes
- Defined target state aligned with OCC 12 CFR 9 requirements
- Rewrote internal policies and created a custody-specific RCSA
- Worked with Technology and Ops to implement workflow logging, approvals, and audit checkpoints
- Built out board-level reporting and committee dashboards (FAC, BMC, ERMC)
- Trained fiduciary officers and risk managers on new oversight procedures
Results
Control Without Disruption. Trust Without Compromise.
- 3-year audit backlog cleared
- OCC exam passed with no findings in Trust Ops
- New fiduciary RCSA framework deployed
- Reduced process risk by 60% via redesign
- Reporting implemented across 4 executive committees
“Laksh helped us satisfy regulators without slowing down the business — a rare blend of compliance and practicality.”
EVP, Trust & Fiduciary Services