PROTECT YOUR CUSTOMERS AND BRAND WITH SMARTER BRAKES Blanket friction is expensive and alienates good customers. Smart friction — targeted, explainable and auditable — protects customers and the brand without taxing everyday behavior. The right 30 seconds at the right time beats three days of post-loss cleanup. Controls on paper don’t act in real time; people and processes do, and 24/7 coverage is essential. Decide whether you’ll use in-house shifts, shared services with your core or fintech partner, or an on-call rotation with explicit SLAs. Decision rights must be clear: Who can pause an outbound? Authorize a one-time limit lift? Contact the member, and from what number? Treat threshold changes like code: ticketed, peer-reviewed and rolled back if friction spikes. Train your team to handle authorized push-payment scams and after-hours escalations until their responses are muscle memory. A 90-DAY BLUEPRINT FOR AUDIT READINESS Examiners and boards want clarity, cadence and control. They expect a one-page program map showing channels in scope, control families, owners and SLAs. Metric trends, including false-positive ratio, true-fraud intercepts, time-to-detect, time-to-recover and loss avoided, should be tracked and reported. Show a playbook excerpt from a real incident and ensure third-party alignment in writing, including transparency, testing rights, change notification and incident notice commitments. • First 30 days: In the first month, inventory every real-time channel and its controls, lock in baseline limits and negative lists, and stand up a single fraud dashboard. • Next 30 days: In the second month, introduce contextual step-ups and behavioral analytics, and run after-hours tabletop exercises with your partners. • Last 30 days: By the third month, tune thresholds based on live data, produce a board or exam packet with metrics and an anonymized case, and set a quarterly cadence for reviews and evidence refresh. This is what “good” looks like to examiners and your board — with these practices in place, you can foster clarity and greater trust. THE BOTTOM LINE Real-time payment rails raised the bar. The institutions that keep their trust advantage will pair speed with discipline: layered controls that act in seconds, an operating model that never sleeps and evidence that stands up on the toughest day. Build the brakes to match the rails, and then show the math — without it, speed becomes risk instead of value. For more industry insights from Plante Moran, scan the QR code. https://www.plantemoran. com/industries/financialservices/banks?utm_source=qrcode&utm_ medium=association&utm_campaign=PENFSG-2026_ICBC We’re here to help. Reach out today! Juliene Wynn, Director of Lending & Compliance (303) 861-4100 juliene@preferredlendingpartners.com preferredlendingpartners.com COLORADO'S BOUTIQUE SBA 504 LENDER SINCE 1984! Preferred Lending Partners is your creative financing connection — helping small businesses to become fixtures in the communities they serve. INDEPENDENT REPORT | 17
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