QI governance & certification — policy stack, control calendar, KRIs & RO brief
Make your QI framework reviewer-ready: a lean policy stack, a clear control calendar, a concise KRI dashboard, and an RO certification brief that aligns with the periodic review.
Scope: Governance tailored to small/mid-sized banks: roles & RACI, policy pack, control calendar, KRIs, issue management, documentation retention,
and RO certification support (aligned to the QI agreement framework and your periodic review cycle).
1) Lean policy stack (what you actually need)
- QI Policy: scope, responsibilities (RO, Tax Ops, IT), definitions, escalation & disclosures.
- QI Procedures: documentation acceptance (W-8/W-9), pooling & rate application, 1042-S creation, corrections, reconciliations.
- Data & Evidence Standard: data dictionary, validations, dossier structure, retention, access control.
- Independence & Conflicts: reviewer independence, advisory separation, acceptance/continuance checks.
Tip: Keep policies short (≤10 pages), procedures modular by process (acceptance, withholding, reporting, reconciliations).
2) Roles & RACI (keep it unambiguous)
| Process | Responsible (R) | Accountable (A) | Consulted (C) | Informed (I) |
|---|---|---|---|---|
| W-8/W-9 acceptance & renewals | Tax Ops | RO | Compliance | Front Office |
| Withholding & pooling rules | Tax Ops | Tax Lead | IT/Data | Finance |
| 1042-S reporting & corrections | Tax Ops | Tax Lead | Compliance/Legal | RO/Board |
| Reconciliations (1042-S ↔ 1042 ↔ GL) | Tax Ops / Finance | Finance Lead | IT/Data | RO |
3) Annual control calendar (pragmatic cadence)
- Monthly: exceptions queue (missing/invalid docs), GIIN match, name/TIN hygiene, KRI review.
- Quarterly: sample QA (acceptance & withholding), mini tie-outs, training refreshers.
- Year-end: 1042-S validations, corrections plan, 1042 preparation, final tie-outs & approvals.
- Cycle: periodic review planning and RO certification alignment (see below).
Evidence: calendar with owners & due dates, sign-offs archived near the reconciliation pack.
4) KRI dashboard (keep it small & useful)
- Documentation: % forms expiring ≤90 days; exception aging >30 days.
- Withholding/Reporting: reject rate (pre-file), corrections count, top-3 error codes.
- Reconciliations: # variances over threshold (gross/tax), time-to-closure.
- Governance: open audit/review issues; training completion rate.
5) RO certification (align to your review)
The Responsible Officer (RO) signs a periodic certification covering the QI’s compliance framework. Align the certification window with your independent periodic review and ensure that issues are tracked to closure with evidence.
- Inputs: latest periodic review report (or readiness memo), issue register, reconciliations, policy attestations.
- Disclosure wording: clear statements on status, exceptions, and remediation (with dates/owners).
- Board/RO brief: one-pager summary + appendix with metrics and closures.
- Retention: keep certification, supporting evidence and approvals under records policy.
Need a ready-to-use governance pack?
Policy templates, control calendar, KRI dashboard (XLSX) & RO certification brief.
Policy templates, control calendar, KRI dashboard (XLSX) & RO certification brief.