How to Build an Agile Change Management Program at Your FI

Change is a constant—whether it’s a new or updated system, regulation, process, product, or vendor. Even small shifts can quickly lead to confusion, risk exposure, and compliance challenges if not properly managed.

That’s why every financial institution needs a change management program that’s both structured and flexible—keeping your team responsive, risk-aware, and in control through every stage of change.

But creating a program is just the beginning. Let’s break down the core elements of effective change management, explore the different types, and look at real-world examples of how financial institutions can put it into practice.

Watch on Demand: Navigating Change: Building an Agile Change Management Program

Table of Contents

• Securing leadership buy-in
• Core elements of a change management program
• Overseeing change for new products and initiatives
• Navigating regulatory change management
• Managing enforcement action-related change

Strong Change Management Starts with Leadership Buy-in

Many financial institutions want to implement change management but struggle to get executive leadership and board members to understand — and champion — why it matters. This is where "tone from the top" comes in.

Begin by building a clear business case that outlines what the change management program is, why it’s needed, and the specific problem it solves. Connect it to broader enterprise risk management goals to show strategic alignment.

Once you have executive and board support, shift focus to securing buy-in from business units and middle management. Make it clear how the program will directly impact their work and why their expertise is essential for success. Each team offers a unique perspective that strengthens the overall program.

Related: A Guide to Governance for Financial Institutions

Structuring for Agility: Core Elements of a Change Management Program

Once leadership is on board, it’s time to structure your program. Every financial institution is different — based on products, services, size, and geography — but these core components are essential for an effective change management program:

• Change identification: Establish a clear process to recognize internal and external changes that could impact your institution.
• Impact analysis and alerting: Assess whether the change applies to your FI and determine its potential impact.
• Responsible party identification: Identify all impacted areas and notify relevant stakeholders across your risk, compliance, audit, and IT teams. Ideally these departments should be represented and involved in every change management committee at your FI.
• Gap identification and action planning: Cross-department conversations help uncover hidden gaps. Once identified, outline the action plan—who’s responsible, what needs to happen, deadlines, and how progress will be tracked and communicated.
• Risk assessment updates: Identify new or existing risks, evaluate and update controls as needed, and revise risk assessments to reflect the changes.
• Ongoing communication and training: Keep teams aligned. Update policies and procedures, assign responsibilities, and deliver targeted training. When in doubt, overcommunicate.
• Testing: Validate that processes and systems perform as expected before full rollout.
• Post-implementation review: Confirm that the change is functioning as intended and establish a process to detect issues and red flags early. Be sure to have a contingency plan in case problems arise. Regulators have been known to cite problems during software rollouts or updates in enforcement actions — particularly when those issues result in consumer harm.

Applying the Change Management Framework to Launching New Products and Initiatives

Change management is also essential when bringing new products and innovations to the market.

While your colleagues may have great ideas — new offerings, digital tools, service improvements — turning those ideas into successful, compliant, and controlled implementation takes structure.

Your existing change management framework provides the structure needed to guide these initiatives from idea to execution, helping you manage risks and ensure the project is aligned with your strategic goals.

Let’s see how each step applies.

Change identification begins with ideation — whether that’s a spark from a customer pain point, market demand, a competitive threat, or internal innovation. The key is recognizing early that a new product or service is more than just a good idea; it’s a formal change that will affect systems, processes, people, and risk profiles.

Next comes impact analysis and alerting, which aligns with evaluating the idea’s feasibility. This includes assessing regulatory requirements, reputational implications, operational complexity, customer experience, and return on investment (ROI). It’s also the point to loop in relevant stakeholders, such as compliance, legal, IT, and marketing, to help uncover issues early and avoid downstream surprises.

Responsible party identification is where the planning starts to take shape. Identify all internal and external parties involved — product owners, compliance reviewers, vendor managers, business line leads — and define roles and responsibilities clearly. This step helps ensure nothing falls through the cracks and everyone understands who’s doing what and when.

From there, you move into gap identification and action planning. As departments collaborate, you’ll likely uncover process gaps, documentation needs, policy updates, or controls that must be adjusted to successfully launch the product or service. This is the moment to map out a plan of action — what needs to happen, who’s accountable, the timeline, and how progress will be tracked and communicated.

With the groundwork in place, it's time to revisit your risk assessment. New products often introduce new risks — whether related to data privacy, vendor dependencies, customer interactions, or operational complexity. Identify those risks, evaluate existing controls, determine where enhancements are needed, and update your risk assessments accordingly.

Ongoing communication and training are essential throughout the process but become especially important as you approach launch. Teams need to understand how the product or service will affect their day-to-day responsibilities. Updated policies, procedures, job aids, and clear training help support a smooth rollout and reinforce consistency. When in doubt, overcommunicate — especially in cross-functional rollouts.

Before going live, invest time in testing. Validate internal processes, confirm system performance, pressure-test customer experiences, and ensure that compliance obligations are fully addressed. If vendors are involved, verify that their controls and commitments align with your expectations.

Finally, after the launch, conduct a post-implementation review. Is the change performing as expected? Are there issues that need resolving? Are controls holding up in a live environment? Use this time to evaluate effectiveness, gather feedback, and make any necessary adjustments. A formal review helps close the loop and provides valuable lessons for future rollouts.

Project Change Management in Action (Fair Lending Example)

Let’s say your FI wants to roll out a new home equity line of credit (HELOC) product, with an initiative to tap into cross-selling opportunities and support non-interest income goals. Here’s what your project change management flow would look like:

• Ideation: The leadership team likely identifies the opportunity based on customer demand, competitive analysis, or market research. The product might include new features, such as interest-only periods or flexible draws.
• Evaluation: Your cross-functional team may ask questions like: What should the product design look like? What terms are competitive yet responsible? What are the regulatory expectations? How do customer disclosures need to be updated? This step is a deep dive to fully understand the implications before committing.
• Planning: At this point, coordination increases. Questions may include: What technology updates are needed in the loan origination system or core platform to support this product? Will operations need new procedures for draw requests, billings, or payouts?
• Building: This step may include configuring systems to reflect the product terms, building workflows for application and underwriting, and drafting updated customer disclosures. During this time, other departments are building in their areas. For example, marketing begins building their campaigns, and compliance reviews the collateral.
• Testing: Does the application process work from start to finish? Are disclosures delivered accurately and on time? Do systems calculate annual percentage rate (APR) and payments correctly?
• Launch: This step might involve a soft launch internally or in a pilot market.
• Ongoing monitoring and auditing: Monitor pipeline volume, customer questions, error reports, and staff feedback. Post-launch reviews help fine-tune the process before broader promotion and ensure the product remains compliant and customer-focused from day one.

Responding to Regulatory Changes

Regulatory change is a constant — and it doesn’t wait for your institution to catch up. By embedding regulatory change management into your broader change framework, you make it easier to respond quickly while minimizing compliance gaps.

• Change identification: Regulatory changes are identified through proactive monitoring — reading the Federal Register, regulator websites, or using automated tools to track changes in real time.
• Impact analysis and alerting: Review whether the regulation applies to your institution. If not, document your conclusion and move on. If yes, assess which departments are affected and begin mobilizing stakeholders.
• Responsible party identification: Assign owners for each aspect of the response — policy, procedures, training, systems, and vendor oversight (if applicable).
• Gap identification and action planning: Determine what needs to change. Will workflows need updates? Are new controls or documentation requirements introduced? Set clear expectations and timelines.
• Risk assessment updates: New regulations may bring new risks — or require adjustments to existing assessments. Incorporate changes into your risk register as needed.
• Ongoing communication and training: Regulatory changes often require organization-wide communication. Ensure teams understand the “what” and “why” behind the change and are trained on new expectations.
• Testing: If the change introduces new controls, test their effectiveness. Confirm that systems, procedures, and staff behaviors align with updated requirements.
• Post-implementation review (monitoring and reporting): Verify that all required actions have been completed and are working as intended.

As always, be sure to document every step — if it’s not recorded, it didn’t happen.

Regulatory Change Management in Action (Example)

Let’s take a look at a recent Office of Foreign Assets Control (OFAC) change as an example. The recordkeeping requirements for certain transactions were updated to 10 years.

Here’s how to ensure this — and similar changes — are properly reflected in your change management program:

1. Monitor for changes. Track regulatory updates by reviewing sources like the Federal Register or using technology that provides alerts. Most changes are announced in advance, giving your institution time to prepare.
2. Conduct an impact assessment. Determine how the change affects your institution. Identify impacted business areas, systems, and processes, such as where records are stored and whether those systems can support a longer retention period.
3. Engage the right stakeholders and create an action plan. Loop in IT, compliance, operations, and any other relevant teams early to align on responsibilities and next steps.
4. Update policies and procedures. Revise documentation to reflect the new 10-year retention requirement.
5. Train affected staff. Provide role-based training so teams clearly understand what’s changed, why it matters, and what’s expected.
6. Test and validate. Confirm that systems and controls have been updated appropriately—such as adjusting system retention settings—and verify that procedures align with the new requirements.
7. Document everything. Maintain a full audit trail showing how the change was implemented, including assessments, decisions, communications, and testing.

Navigating Enforcement Actions

Enforcement actions are more than formal measures regulators take against FIs — they’re also valuable learning tools. They highlight common pitfalls and emerging regulatory trends, helping your institution make changes to strengthen compliance and risk management programs and avoid similar missteps.

When reviewing an enforcement action as part of your FI’s change management process, follow these steps:

• Identify: Enforcement actions are posted monthly on regulatory agency websites. The Ncontracts Enforcement Action Tracker also provides timely, plain-language summaries of recent enforcement actions from key regulators.
• Analyze: Consider what the action says, what deficiencies were identified, and what corrective steps the financial institution was required to take.
• Perform an impact analysis: Ask yourself: Does this enforcement action apply to my institution? Does it involve a service we offer or a regulation that applies to us? If so, identify which departments are affected.
• Consider a control assessment: Evaluate your existing controls. Do you have enough/sufficient controls in place to ensure that violation doesn’t occur at your institution? If not, now is the time to establish them.
• Review policies and procedures: Determine if your policies and procedures align with regulatory requirements highlighted in the enforcement actions. If there are gaps, update them as needed.
• Training and controls: After reviewing the enforcement action, do you see similar weaknesses in your processes? Controls may need to be added or improved. Staff might need new or additional training. Such training should be tailored by role. For instance, a teller on the front line likely needs different training than someone in loan operations.
• Monitoring and testing: When new controls are implemented, test them to confirm they work as intended. Then, establish an ongoing monitoring plan. Higher-risk areas may require monthly or quarterly reviews, depending on your internal program.
• Ongoing risk assessments: Whether it’s a new risk or a new control, those updates should be reflected in your risk assessments. Reviewing enforcement actions should be a dynamic, recurring part of this process, not a once-a-year task.

Related: Expert Q&A: How to Build a Risk Assessment

Enforcement Action Change Management in Action (BSA/AML/CFT Example)

In February 2025, the Office of the Comptroller of the Currency (OCC) found several deficiencies in an institution’s Bank Secrecy Act (BSA) and Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) programs.

The FI lacked a written Customer Identification Program (CIP) and documented processes for filing Suspicious Activity Reports (SARs). Additionally, the FI didn’t include BSA/AML/CFT elements when launching new products and services.

Using the above steps, let’s review this enforcement action through the lens of change management:

• Evaluate how the enforcement action impacts your institution. Determine whether you have a CIP policy and SAR process in place.
• Assess whether your programs include all required elements and controls to mitigate risk.
• Update policies and procedures based on the identified deficiencies and ensure the compliance and BSA teams are involved in product development decisions.
• Ensure employee training is current and tailored to specific roles. Determine if any new controls are needed.
• Test any new controls after implementing a new program or product and continue with regular monitoring.
• Update your risk assessments to reflect any findings or changes, including newly implemented controls.

Conclusion: Make Change Easier to Manage

Change isn’t slowing down — and neither should your financial institution’s ability to manage it. Whether you’re responding to shifting regulations, launching new products, or learning from enforcement actions, a well-structured, repeatable change management program helps you stay agile, compliant, and in control.

It gives your financial institution the ability to respond efficiently — without reinventing the wheel each time something shifts. When everyone understands the steps, responsibilities are clear, and communication is built in, change becomes easier to manage, less risky, and far more efficient.

It’s not just about reacting faster — it’s about anticipating what’s coming, building alignment across teams, and embedding risk awareness into every decision. With the right framework in place, change becomes more than something to manage. It becomes an opportunity to strengthen your institution.

Want more insights on how your FI can navigate changes? Download our enterprise risk management (ERM) buyer’s guide.