Field Notes
Control owners matter more than polished policy binders
Policy binders reassure visitors. Control owners keep money reconciled. In audits for fintech groups, we regularly meet beautifully formatted reconciliation policies that still fail because no named person is expected to clear exceptions before the next close.
Signs ownership is unclear
- The same break item rotates between ops and finance for weeks
- Escalation emails go to a shared inbox with no response SLA
- Month-end depends on one person who holds undocumented knowledge
A lighter fix than rewriting everything
Keep the policy. Add a one-line owner and backup for each critical control. Publish the list inside the close checklist. When we test samples, we interview the named owner — not the author of the binder — and the conversation becomes concrete within minutes.