Regulatory Obligation-to-Control Mapping
Parse a regulation, exam manual, or guidance into discrete obligations and map each to an owned internal control - with control type, coverage status, gaps, UDAAP flags, and a citation on every line.
Mapping a regulation or exam-manual module to internal controls - line-by-line obligation parsing and control coverage that took analysts weeks of manual cross-referencing - produced in minutes per source, with a citation and coverage status on every obligation
per authoritative source
What it extracts
8 extraction fields
- Authority Source Summary
- A one-look roll-up of the source being mapped - its title, type, issuing authority, root citation, effective date, applicable products, jurisdiction, and the control library it is mapped against - so a reviewer can orient before the register and matrix.
- Obligation Register
- The authoritative source parsed into atomic obligations, one per row, each with a stable ID, its specific citation section, a plain-language summary, an obligation type, whether it is mandatory or conditional, and its applicability trigger.
- Obligation-to-Control Mapping
- The core matrix - every obligation mapped to the internal control or policy that satisfies it, with the control owner, control type (preventive/detective/corrective), control nature, a computed coverage status, and supporting evidence; obligations with no adequate control are marked as gaps.
- Control Gap Register
- Every obligation that is a gap or only partially covered, risk-rated for compliance and consumer-harm exposure, with the recommended control, its recommended type, and a suggested owner to close it.
- UDAAP Risk Overlay
- A UDAAP screen over the obligations and described practices under Dodd-Frank 1031/1036, applying the unfair/deceptive/abusive three-part standards to flag exposure (including disclosures that are present but buried or diluted) with a rationale and a recommended mitigation.
- Regulatory Change Impact
- When a prior version is provided, the new, amended, removed, or reaffirmed obligations versus the prior source, the controls each change affects, and the control-library update required - the trigger for re-mapping when a regulation changes.
- Overall Coverage Status
- A single coverage verdict for the source - fully mapped, substantially mapped with minor gaps, material gaps identified, control library not provided, or needs manual review - weighting mandatory and high-risk obligations most heavily.
- Mapping Exceptions and Remediation
- The remediation workpaper - one row per gap, partial coverage, UDAAP flag, or unresolved change, each with its citation, a severity, a concrete remediation step, an owner, and a target date.
Where it fits
Regulatory change management and compliance control mapping
Upstream
Regulatory intake - a new or amended authoritative source (regulation, CFPB examination-manual module, or guidance) is identified by regulatory-change management and queued for mapping
This step
Obligation-to-control mapping (authority-document mapping)
Downstream
- Control build-out and remediation of identified gaps
- Compliance Testing / control testing against the mapped controls
- Examination and audit readiness (coverage evidence)
What it needs
Documents
- Authoritative source - a regulation or rule, examination manual / supervisory-procedure module, or guidance/bulletin
- Internal control, policy, and procedure library (the mapping target)
- Prior version of the source or prior mapping (for change impact)
Systems
- GRC / compliance-mapping platform
- Policy and procedure repository
- Regulatory-change-management system
Prerequisites
- The authoritative source to be mapped
- The institution's control / policy / procedure inventory to map against (obligations can be parsed without it, but coverage cannot be scored)
- A control-owner taxonomy (the functions accountable for controls)
What it produces
A regulatory obligation-to-control mapping - an obligation register, an obligation-to-control matrix with owner, control type, and coverage status, a gap register, a UDAAP overlay, a change-impact list, an overall coverage verdict, and a cited remediation workpaper
Delivered to
- GRC / control-inventory system
- Remediation / issue tracker
- Examination and audit workpapers
Review model
A compliance mapping analyst reviews the parsed obligations, the control mappings, the gap and UDAAP findings, and the cited sections before the mapping is trusted and gaps are routed to owners for remediation.
Who uses it
Volume fit
Works best for
compliance and GRC teams maintaining mappings across many regulations, exam-manual modules, and guidance documents, and re-mapping each time a source changes
Too small for
a one-off read of a single short bulletin with no control library to map against
Grounded in
- Dodd-Frank Wall Street Reform and Consumer Protection Act, sections 1031 and 1036 (12 U.S.C. 5531, 5536) - UDAAP prohibitionverified as of 2026-07-22
- Truth in Lending Act / Regulation Z, 12 CFR 1026.60 (Credit and charge card applications and solicitations - Schumer box)verified as of 2026-07-22
- Regulation Z, 12 CFR 1026.6(b) (Account-opening disclosures)verified as of 2026-07-22
- Truth in Savings Act / Regulation DD, 12 CFR 1030.4 (Account disclosures)verified as of 2026-07-22
- Electronic Signatures in Global and National Commerce Act (E-SIGN), 15 U.S.C. 7001 (consumer consent to electronic records)verified as of 2026-07-22
- CFPB Supervision and Examination Manual - UDAAP examination procedures and Compliance Management Review modulesverified as of 2026-07-22
Changelog
- July 2026
based on a production deployment at a consumer lending & card issuer
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