A Guide for Managing Multidisciplined Consent Orders

Financial services organizations can better navigate the demands of multidisciplined consent orders through strong governance, cross-functional collaboration, and regulatory engagement.

Multidisciplined consent orders are becoming increasingly complex because they reflect broader organizational challenges rather than isolated control failures. These orders often reveal systemic breakdowns across multiple domains including compliance, risk management, operations, and technology. Successfully managing multidisciplined consent orders requires more than technical remediation; it demands centralized oversight, cross-functional collaboration, and organized execution across every affected area of the organization.

The consequences of mishandling a consent order are serious. Organizations that fail to respond effectively can face escalating penalties, prolonged supervisory scrutiny, reputational harm, and operational disruption. A multidisciplined regulatory enforcement action (such as a consent order or written agreement) is often caused by persistent deficiencies in, for example, risk management, compliance, and internal controls, and it can result in various regulatory remedies, including restrictions on dividends. Because these types of consent orders affect multiple interconnected parts of a business, resolving them demands more than corrective action in silos; it requires holistic, well-orchestrated execution.

However, a consent order doesn’t have to be a crisis. With the right governance structure, cross-functional collaboration, and forward-looking strategy, organizations can meet regulatory expectations, strengthen their internal processes, and emerge more resilient. With appropriate, proactive planning, organizations can successfully manage a multidisciplined consent order, from understanding its scope to implementing a robust remediation plan, engaging with regulators, and facilitating long-term compliance.

Understanding the consent order

The first critical step in responding to a multidisciplined consent order is to achieve a comprehensive understanding of the order itself. These orders often encompass a broad range of obligations, each with their own unique regulatory expectations. Without fully interpreting the expectations and accurately mapping their impact across the organization, organizations can risk delays in execution, heightened regulatory scrutiny, and potential reputational harm.

Conducting a thorough gap assessment of the areas under the consent order and reviewing existing policies, control frameworks, operational procedures, and governance structures help identify where gaps exist. Importantly, obligations should not be treated as one uniform task without distinction or structure. Instead, they should be broken down into discrete, actionable components and categorized by business function. Doing so creates a manageable structure that promotes accountability, enables functional ownership, and lays the groundwork for efficient planning and delivery.

Establishing centralized governance

Establishing a structured governance framework is critical for coordinating remediation efforts, enforcing accountability, and maintaining alignment across diverse workstreams. With remediation efforts spanning multiple functions, it is critical to establish a clear governance framework that brings stakeholders from all affected areas into a cohesive oversight structure.

This governance function can serve as the central point of coordination for the entire response. It also should be responsible for aligning remediation activities with regulatory expectations, tracking progress against milestones, and resolving interdependencies between workstreams. Equally important, this function can enable early identification and escalation of risks or delays that could hinder execution of remediation activities.

Regular, structured communication is another critical element of managing a multidisciplined consent order remediation team. The team overseeing governance should maintain ongoing dialogue with executive leadership to help facilitate informed and engaged decision-making throughout the process. The framework also should support consistent, transparent communication with regulators and provide timely updates, documentation, and evidence of progress.

In addition, quality assurance should be embedded into the governance process to confirm that remediation efforts are executed with rigor and meet both internal standards and supervisory expectations. With centralized governance in place, organizations can achieve a coordinated response that is disciplined and credible and position themselves to meet the demands of the consent.

Developing and executing a remediation program

An effective remediation program begins with disciplined analysis. As noted, the remediation process for addressing a multidisciplined consent order begins with conducting a gap assessment across all affected domains and comparing existing practices to regulatory expectations to uncover compliance deficiencies. A root cause analysis follows, ideally designed to identify the underlying governance, process, or control failures that led to the findings. Without understanding the root causes, any corrective actions risk being temporary or ineffective.

Once organizations understand root causes and compliance gaps, they can translate insights into a remediation road map. This road map should outline clear deliverables aligned with each obligation, define ownership, and establish realistic, yet firm timelines. Effective prioritization is essential, as certain issues might require immediate attention due to regulatory urgency or elevated risk exposure while others can be addressed through a sequenced, long-term approach. The road map should form the foundation of a broader compliance action plan and be developed collaboratively with input from each affected business line to make sure it is comprehensive and achievable.

At this stage, assembling the right team is crucial. Organizations should consider building remediation teams that are equipped to address the complexities of the affected business lines. These teams need clearly defined roles, shared tools and templates, and coordinated interdependencies to avoid miscommunication and delays. Effective leadership is critical in setting expectations, aligning timelines, and maintaining momentum. In some cases, especially when specialized knowledge or bandwidth is limited, organizations might benefit from bringing in third-party support to augment internal capacity and evaluate the quality and credibility of complex remediation activities.

Many financial services organizations face challenges during the execution of remediation plans due to insufficient follow-through. To avoid this problem, organizations should enforce rigorous project management discipline, including tracking milestones, escalating issues promptly, and confirming that ownership is maintained throughout the life cycle of each remediation item. Transparent tracking mechanisms such as dashboards, scorecards, or regular status reports should be used to give stakeholders and regulators clear insight into progress and accountability.

Reporting and regulatory communication

One of the most important yet often overlooked elements of managing a multidisciplined consent order is regulatory communication. It is not enough to simply make progress; organizations should demonstrate progress clearly, consistently, and proactively across multiple reporting levels. Effective communication can help all stakeholders, from internal leadership to external regulators, remain aligned and confident in the organization’s trajectory toward full remediation.

Clear, structured reporting starts with creating a dedicated reporting workstream responsible for consolidating updates from across the various functional teams. The workstream should establish and maintain a single source of truth for consent order status and associated documentation, and it should substantiate evidence of completion. This centralized function should facilitate structured reporting to help the organization achieve consistency and accuracy in all communications.

Reporting should occur at several levels:

• Internal reporting. Senior management and boards of directors need routine, digestible summaries of consent order progress, key risks, and upcoming milestones. These internal updates should enable informed oversight and support timely resource allocation and escalation where needed.
• Reporting to subject-matter experts (SMEs). Functional SMEs require detailed, tactical reporting that informs them of their specific areas of responsibility. These updates support operational execution, promote accountability, and ensure alignment between technical progress and overall consent order objectives.
• Regulatory reporting. Regular updates to regulatory exam groups must be structured, fact-based, and aligned with regulatory expectations. These reports should include status updates, implementation metrics, and supporting documentation that clearly demonstrate closure criteria are being met. Organizations should also be prepared to walk regulators through the rationale behind decisions made and how controls are being embedded for sustainability.
• Legal and compliance reporting. Communication with in-house and external legal counsel is crucial. All representations made to regulators must be accurate, appropriately framed, and protective of the organization’s legal posture. Compliance teams also rely on targeted updates to monitor adherence to regulatory commitments and identify emerging risks. 

Beyond regular reporting cycles, organizations should engage regulators proactively. When obstacles arise, requirements evolve, or timelines shift, transparency is critical. Timely self-reporting of emerging issues accompanied by concrete remediation plans and root cause analyses demonstrates integrity and a commitment to sustainable improvement.

Communication should be coordinated, accurate, and reflect a unified message across the remediation team. Fragmented or inconsistent messaging undermines credibility and can lead to increased regulatory scrutiny. A well-structured, multilevel reporting framework can help confirm that progress is clearly conveyed and reinforce the organization’s overall governance, risk management, and compliance culture.

Managing challenges and adjustments

Even the most comprehensive plans face unexpected challenges. Organizations should remain adaptable and ready to pivot as needed. Common roadblocks include resource constraints in high-demand areas such as data governance or technology, quick fixes that don’t meet sustainability expectations, and competing business priorities that distract from remediation efforts.

Addressing these challenges requires a balance of strategic agility and operational discipline. Organizations should not hesitate to revisit timelines, reallocate resources, or refine their remediation scope based on evolving insights. If timelines or deadlines do change, it is imperative that the board and senior management are apprised immediately to support continued oversight and alignment with priorities. When capacity is stretched, working with experienced third-party providers can provide the necessary lift. Most importantly, creating a culture of cross-functional collaboration and transparency helps surface issues early and encourages collective problem-solving.

Ensuring continual improvement and compliance

Fulfilling the requirements of a consent order is not the end of the journey. Rather, it is the start of a more resilient compliance framework. Organizations must implement controls for continual improvement to avoid regression and help lessons learned translate into lasting change.

Ongoing monitoring is critical, especially in areas previously flagged by regulators. Such monitoring includes internal control testing, management reviews, and ongoing assessments of high-risk areas. Regular audits, both internal and external, can help validate the sustainability of remediation and help fixes remain effective over time.

Investing in people is equally critical. Ongoing training, clear policies, and a shared understanding of compliance expectations help embed the cultural shift that regulators expect after remediation. Continuing to engage proactively with regulators and offering updates, evidence, and transparency can help organizations reinforce their credibility and demonstrate long-term commitment to compliance and risk management.

Turning pressure into progress

Multidisciplined consent orders are complex, high-stakes challenges; however, they are entirely manageable with the right structure, strategy, and leadership. By establishing strong governance, building collaborative remediation programs, proactively communicating with regulators, and embedding a culture of continual improvement, organizations can transform a consent order from a crisis into a catalyst for organizational resilience.

Managed correctly, a consent order can both resolve a problem and become an opportunity for an organization to emerge stronger, more aligned, and better prepared for the future.