Risk_Taxonomy_ID	Risk_Taxonomy_Level_1	Risk_Taxonomy_Level_2	Metric	Signal_Source
1	Unauthorized Activity	Unauthorized account opening and closing	# of account opened spikes and is inconsistent with historical performance or market sentiment	Acct Activity (Open/Close/Fund)
3	Unauthorized Activity	Unauthorized account activity	# of duplicate accounts by branch / region	Investigations
4	Unauthorized Activity	Unauthorized account opening and closing	# of accounts closed with no activity (not consistent with historical observation) / Spike in number of dormant accounts with balance below a threshold	Acct Activity (Open/Close/Fund)
5	Unauthorized Activity	Insufficient Customer Consent	# of accounts down graded when employee receives credit	Acct Activity (Open/Close/Fund)
6	Unauthorized Activity	Unauthorized account activity	# of  accounts with employee activity after business hours of operation by branch / region	Acct Activity (Open/Close/Fund)
7	Unauthorized Activity	Insufficient Customer Consent	# of accounts opened with no customer acknowledgement	Acct Activity (Open/Close/Fund)
8	Unauthorized Activity	"Funding Manipulation / 
Simulated Funding"	# of accounts that do not meet the  funding requirements within defined time period 	Acct Activity (Open/Close/Fund)
10	Unauthorized Activity	Unauthorized account activity	# of applications accessed / opened from unauthorized computers trying to access the system 	Acct Activity (Open/Close/Fund)
12	Unauthorized Activity	"Funding Manipulation / 
Simulated Funding"	# of customers funding accounts in a cadence and withdraw the fund	Acct Activity (Open/Close/Fund)
13	Unauthorized Activity	Insufficient Customer Consent	# of customers who default within first 3 / 6 / 9 months overall	Acct Activity (Open/Close/Fund)
15	Unauthorized Activity	Insufficient Customer Consent	# of accounts that have been funded and funds transferred within 30 / 90 days of opening	Acct Activity (Open/Close/Fund)
17	Unauthorized Activity	Insufficient Customer Consent	# of accounts opened after the date when credit is applied	Acct Activity (Open/Close/Fund)
19	Unauthorized Activity	Insufficient Customer Consent	# of accounts open for customers who do not qualify (# of unauthorized credit inquiries)	Acct Activity (Open/Close/Fund)
20	Unauthorized Activity	Insufficient Customer Consent	# or % of accounts closed within 30/60/90 days of opening	Acct Activity (Open/Close/Fund)
21	ALL	Insufficient Customer Consent	"# or % of allegations of employee involvement in sales practice misconduct (by region, product etc.)"	Investigations
22	Unauthorized Activity	Insufficient Customer Consent	% of accounts closed without documented client consent (by LOB)	Acct Activity (Open/Close/Fund)
23	Unauthorized Activity	"Funding Manipulation / 
Simulated Funding"	"% of accounts with excessive or unusual balance transfers, including transfers from accounts other than those of the customer"	Acct Activity (Open/Close/Fund)
24	Unauthorized Activity	False Entries / CIP (Customer Idenfitication Program) Violations	"% of CIP violations (lack of entries for name, DOB, address,  identification number at minimum) in relation to the # of accounts opened"	Acct Activity (Open/Close/Fund)
25	ALL	ALL	% of employee turnovers by branch or region	Employee Separation
26	ALL	Other	# of sales practices trainings by delinquency (30-60-90 days)	Employee Training
28	Employee Misrepresentation	"Funding Manipulation / 
Simulated Funding"	% of new accounts that have made only minimum payments for the first 6 months	Acct Activity (Open/Close/Fund)
29	Employee Misrepresentation	Falsifying customer information	Age of customers when opening a credit card (to verify if those under 21 provided signature when opening account)	Investigations
31	ALL	Other	"Investigation by status (No action, open, pending, resulted in action)"	Investigations
32	Employee Misrepresentation	Targeting Inappropriate Customer	"# of account applications that were started and not completed, including timing of account application start date and incentive plan timing"	Acct Activity (Open/Close/Fund)
33	Inappropriate Sales Tactics 	Targeting Inappropriate Customer	# of accounts having monthly repayment amounts as high percentage of customer disposable income	Acct Activity (Open/Close/Fund)
34	Inappropriate Sales Tactics 	Product Manipulation	# of accounts sold through unnecessary bundling of products and unusual product mix	Acct Activity (Open/Close/Fund)
35	Employee Misrepresentation	Targeting Inappropriate Customer	# of accounts with steady increasing debt while making minimum payments	Acct Activity (Open/Close/Fund)
36	All	Misinformation of product	# of customer complaints that remain unresolved related to product dissatisfaction	Customer Complaints
37	Inappropriate Sales Tactics 	Targeting Inappropriate Customer	# of customers identified to be high risk in relation to total accounts opened during sales incentive program	Investigations
38	Inappropriate Sales Tactics 	Misrepresentation of Product to customer	"Mismatch of customer's profile, based on peer analytics. Profile does not seem to align with the product"	Acct Activity (Open/Close/Fund)
39	Inappropriate Sales Tactics 	Product Manipulation	"# of customers who received a credit card through cross selling, who would not have qualified through an invitation-to-apply process"	Acct Activity (Open/Close/Fund)
40	Employee Misrepresentation	Targeting Inappropriate Customer	# of customers who were full balance payers for consecutive months and then  switched to minimum payers	Acct Activity (Open/Close/Fund)
41	Inappropriate Sales Tactics 	Misinformation of product	# of lower quality accounts (Rolling Funding Rate metric) and the rate of sales practice misconduct	Investigations
42	Inappropriate Sales Tactics 	Targeting Inappropriate Customer	% of sales of new products to customers over age 65 / vulnerable classes	Acct Activity (Open/Close/Fund)
43	Inappropriate Sales Tactics 	Aggressive Sales Tactics	"% of sales penetration (by products and services such as paperless statements) with sensitive classes (such as customers with limited credit options, elderly, service members)"	Acct Activity (Open/Close/Fund)
44	Inappropriate Sales Tactics 	Aggressive Sales Tactics	% or # cross-sales made to customers with multiple existing products (illogical sales) by region or branch	Acct Activity (Open/Close/Fund)
45	Inappropriate Sales Tactics 	Misinformation of product	"% or # of customer complaints related to specific products, or employees"	Customer Complaints
46	Inappropriate Sales Tactics 	Product Manipulation	"Product Sales volumes, made to intended or typical age range within target market, exceeds predicted volumes"	Acct Activity (Open/Close/Fund)
47	Employee Misrepresentation	Product Manipulation	Review transactions to identify # of products that have not been activated after 30/ 90 days	Acct Activity (Open/Close/Fund)
48	Inappropriate Sales Tactics 	Misinformation of product	Total product sales volumes within 3 months of marketing campaign in relation to predicted amounts (above or below predicted amounts)	Acct Activity (Open/Close/Fund)
49	Inappropriate Sales Tactics 	Product Manipulation	# of products with high probabilty of sales practices risk	Investigations
50	Inappropriate Sales Tactics 	Misrepresentation of Product to customer	Total # of mismatches of marketing information with product attributes	Investigations
51	Employee Misrepresentation	Creation of Unnecessary Accounts	"# of account applications that were declined/failed during account opening process, including timing of account application start date and incentive plan timing "	Acct Activity (Open/Close/Fund)
53	Unauthorized Activity	Incentive / Compensation Manipulation	 # of associated sales person receiving  sales bonus after each funding activity	Sales and Employee Incentive
54	Unauthorized Activity	Creation of Unnecessary Accounts	# of accounts associated with existing customers and timing of the openings	Acct Activity (Open/Close/Fund)
56	Unauthorized Activity	Incentive / Compensation Manipulation	# of accounts opened through a sales practice incentive program	Sales and Employee Incentive
57	Unauthorized Activity	Incentive / Compensation Manipulation	"# of accounts opened towards the end of an incentive period, trend in sales by  business units, close to the end of the month/quarter when sales targets are measured"	Sales and Employee Incentive
58	Inappropriate Sales Tactics 	Sales Pressure / Incentive / Compensation Manipulation	# of accounts/products sold with a disproportionately high number of accepts within the first and last few days of the incentive period	Acct Activity (Open/Close/Fund)
59	ALL	Sales pressure	"# of bankers who received coaching, counseling, reprimands, warning, and/or written warning for S.P misconducts"	Investigations
60	Unauthorized Activity	Incentive / Compensation Manipulation	# of credit cards  product fee refunds - rate of refunds per employee each month	Acct Activity (Open/Close/Fund)
61	Unauthorized Activity	Incentive / Compensation Manipulation	# of credit Cards  product interest refunds - rate of refunds per employee each month	Acct Activity (Open/Close/Fund)
64	High Pressure Environment for Employees	Incentive / Compensation Manipulation	# of whistleblower complaints related to gaming of incentive plans	Employee Complaints
65	Unauthorized Activity	Incentive / Compensation Manipulation	% accounts closed after opened and funded account or after the associated sales person obtained sales bonus	Acct Activity (Open/Close/Fund)
66	Unauthorized Activity	Incentive / Compensation Manipulation	% accounts dormant after opened and funded account or after the associated sales person obtained sales bonus	Acct Activity (Open/Close/Fund)
67	High Pressure Environment for Employees	Employee complaints	% and/or # of employee complaints related to sales targets/ pressure	Employee Complaints
68	Unauthorized Activity	Incentive / Compensation Manipulation	% of accounts opened that only meet the minimum required funding amount	Acct Activity (Open/Close/Fund)
69	Inappropriate Sales Tactics 	Referrals pressure	"% of customers receiving referral incentives, amount spent for referral incentives, i.e. ""Refer a friend to our services and receive $500"""	Sales and Employee Incentive
71	High Pressure Environment for Employees	Incentive / Compensation Manipulation	% of employees exceeding sales targets by 10%	Sales and Employee Incentive
72	ALL	ALL	% of involuntary employee separation due to S.P. related employee misconduct	Employee Separation
74	High Pressure Environment for Employees	Employee complaints	% of voluntary employee separation due to management misconduct	Employee Separation
75	ALL	Sales pressure	"% or # of sales targets that are barely but consistently met and variations across regions, business units and individuals"	Sales and Employee Incentive
76	ALL	Sales Pressure / Incentive / Compensation Manipulation	"Customer feedback trends by channel (i.e. call center, branch, social media)"	Customer Complaints
78	High Pressure Environment for Employees	Employee complaints	Rate of employee dis-satisfaction	Employee Feedback
80	Unauthorized Activity	Creation of Unnecessary Accounts	# of customers who were previously active on cards but no longer use it	Acct Activity (Open/Close/Fund)
83	Employee Misrepresentation	Incentive / Compensation Manipulation	% of fee waivers applied each month by employee	Acct Activity (Open/Close/Fund)
84	Employee Misrepresentation	Falsification of accounts	# of accounts closed with the account closure reason of account opened in error without any explanation as to what the error was	Acct Activity (Open/Close/Fund)
86	Unauthorized Activity	Falsification of accounts	# of accounts opened and closed by the same banker	Acct Activity (Open/Close/Fund)
88	Employee Misrepresentation	Falsification of accounts	"# of accounts that failed Experian, but passed the out of pocket questions to open the account and banker associated with the account opening "	Acct Activity (Open/Close/Fund)
89	Employee Misrepresentation	Falsification of accounts	# of accounts that have high risk funding source	Acct Activity (Open/Close/Fund)
90	Employee Misrepresentation	Falsification of bank records	# of accounts that list branch or employee addresses as mailing address during application process	Acct Activity (Open/Close/Fund)
91	Employee Misrepresentation	Falsification of bank records	"# of accounts that list incorrect email addresses during application process (branch, employee or other invalid email address not match customer profile)"	Acct Activity (Open/Close/Fund)
92	Employee Misrepresentation	Falsification of bank records	# of accounts with incomplete account information	Acct Activity (Open/Close/Fund)
93	Employee Misrepresentation	Falsification of accounts	"% approval rates, look for outliers"	Sales and Employee Incentive
94	Employee Misrepresentation	Falsification of accounts	# of colleagues with non-typical spread of loan type more longer term over shorter term loans compared to average	Sales and Employee Incentive
95	Employee Misrepresentation	Misrepresentation of sales / quotas	# of customers still on variable rollover product 6/12 months after rate expires	Acct Activity (Open/Close/Fund)
96	Unauthorized Activity	Incentive Manipulation	# of customers who have a fee refund within the first 13 months overall/per colleague	Acct Activity (Open/Close/Fund)
97	Employee Misrepresentation	Falsification of bank records	# of follow-ups documented in relation to # of customer complaints	Customer Complaints
98	Employee Misrepresentation	Falsification of accounts	"# of transactions with a high accept rate, but low Call Handling Time"	Acct Activity (Open/Close/Fund)
99	Employee Misrepresentation	Incentive Manipulation	"# of transactions with a high offer rate, but low conversion rate"	Acct Activity (Open/Close/Fund)
100	Employee Misrepresentation	Falsification of bank records	# of whistleblower cases that remain unresolved	Employee Complaints
101	Employee Misrepresentation	Falsification of bank records	"% of accounts with change in profile information (email, addrress, pin etc. )"	Acct Activity (Open/Close/Fund)
102	Employee Misrepresentation	Falsification of bank records	% of accounts opened with nothing scanned in for NAO (National Audit Office?) documents and the name of banker associated	Acct Activity (Open/Close/Fund)
103	Employee Misrepresentation	Falsification of bank records	% of offer accepts that occurred on a different date from the call date 	Acct Activity (Open/Close/Fund)
104	Unauthorized Activity	Other	"Outliers in wire transfer amounts per account, A single wire transfer with high-value transaction amount "	Acct Activity (Open/Close/Fund)
105	All	All	Customer feedback by risk taxonomy topic	Customer Complaints
