Playbook: 90-day roadmap to audit readiness for an MVP
90-day roadmap to audit readiness for an MVP shows FinTech teams how to triage controls, run remediation sprints, and build
examiner-ready proof packets in 90 days.
Introduction
Auditors break launches.
MVP teams hit unexpected exam requests that stall releases and burn runway. This 90-day roadmap to audit readiness for an MVP gives a time-boxed, actionable plan to produce examiner-ready artifacts in 90 days.
By following four phases — kickoff, controls triage, remediation sprints, and a pre‑exam mock — you’ll reduce regulator risk and keep product velocity.
Expect tangible outcomes by Day 90: prioritized tickets, proof packets, and a regulator-ready one-page narrative.
Why a Focused 90-Day Effort Works
A 90-day plan forces choices.
It concentrates resources on controls that actually block releases and turns vague requirements into testable tasks.
Compared with ad-hoc legal advice, this approach produces clear owners, acceptance criteria, and evidence. Compared with hiring a full-time CCO, it’s faster and cost-effective for an MVP that needs immediate coverage.
Measure success with objective criteria: percent of high-priority controls covered, completeness of evidence packets, and time-to-evidence during a mock exam.
Anchor your control mapping to regulator materials so examiners see you followed a recognized standard. For transaction monitoring and AML scoping, map work to the FFIEC BSA/AML examination procedures. For consumer finance pitfalls, reference CFPB Supervisory Highlights.
This plan also fits into two-week engineering sprints. Each remediation ticket becomes a sprint story with a “definition of done” that requires an artifact, a test, and an updated policy. Think of your exam binder like a flight manual. You want clear checklists, not a novel.
Note: Treat this as a product project. Prioritize like a PM and time‑box decisions.
Step 1 — Kickoff & Rapid Intake (Weeks 0–2)
Day 0: Executive triage and alignment
Run a 60–90 minute kickoff with COO, GC, product lead, and head of engineering.
Start with a simple question: “What single release needs regulatory coverage first?”
Capture the top five regulatory risks and any open regulator communications.
Assign owners for each risk and link them to Jira tickets. Produce a one-page executive summary listing priorities, owners, and sprint milestones.
That summary is your north star.
Example dialogue from a kickoff:
- COO: “What blocks the September release?”
- Product: “We don’t have exportable KYC logs.”
- GC: “Regulators will ask for our sampling methodology.”
- Compliance owner: “We’ll map these to evidence this week.”
This kind of rapid alignment prevents scope creep.
A short, realistic scenario: David, the COO, learns in this meeting that KYC exports and refunds flow evidence are missing for the next release. Within 48 hours, the team opens three tickets, assigns owners, and sets a sprint goal. They now have focus — and a clock.
Day 1–7: Evidence and artifact collection
Tell teams to gather a focused artifact set.
Use bullets to make the ask concrete:
- Policies and procedures
- Onboarding flows and disclosures
- KYC rules and decision logic
- Sample transaction records (last 12 months)
- Authentication and access logs
- Vendor contracts and SOC reports
- Privacy notices and consent screens
Be specific: ask for the last 12 months of relevant logs, recent change tickets, and signed third‑party attestations.
Use a shared drive with a simple intake template to make artifacts searchable and versioned. If you need a starter template, adapt open-source trackers from GitHub. For AWS-hosted systems, collect cloud compliance exports through AWS Artifact and AWS Audit Manager to avoid manual pulls.
Flag evidence that proves core controls: KYC checks, disclosures, data retention, and vendor SOCs. Label each file with product, control family, and date to speed retrieval.
Quick win: Ask each owner to produce one example proof packet within 48 hours. A proof packet is a small folder with screenshots, logs, a policy snippet, and the related ticket ID. One complete packet early builds momentum.
Day 8–14: Rapid gap analysis and prioritization
Map artifacts to control families — consumer protection, privacy, AML, and cybersecurity.
Score each gap by impact and ease of fix: high/medium/low impact and easy/medium/hard to fix. This creates objective prioritization and removes debates.
Produce a day‑14 prioritized plan with sprint milestones and a one‑page regulator summary.
That document should include ticket IDs, required artifacts, and owners for each sprint. Keep it to one page so leaders actually read it.
From experience, teams that include time-to-evidence as a metric move faster. Can you pull a log, a sample, and a policy excerpt within 24 hours?
Step 2 — Controls triage & stabilization (Weeks 3–5)
Triage the controls that block releases
Pick 3–5 controls that block product launches: required disclosures, refunds and dispute flows, KYC/AML screening, and data retention. For each, define an interim compensating control to reduce immediate examiner exposure.
Example quick fix: If automated KYC exports are missing, enforce a manual KYC review queue with documented decision notes and sample screenshots. Log a Jira ticket with explicit acceptance criteria and the artifacts that will prove remediation.
What to avoid: vague fixes with no evidence path. If you can’t show it, it didn’t happen.
Stabilize systemic security and process issues
Harden production defaults.
Do the basics well:
- Enforce least privilege.
- Enable structured logging.
- Disable debugging endpoints.
Map these actions to the NIST Cybersecurity Framework (CSF) to show a recognized baseline.
Automate evidence capture. For teams on AWS, configure CloudTrail, Config, and AWS Audit Manager to produce exportable logs and change histories.
Run tabletop tests or peer reviews to validate interim processes. SANS publishes practical scripts and checklists you can adapt.
Note: Tie each security change to a ticket and a named owner. It keeps the paper trail clean.
Prepare a concise regulator narrative
Draft a one‑page narrative that explains how issues were found, the remediation approach, and the timeline to permanent fixes. Attach sample artifacts and reference Jira IDs for each claim. Keep sentences short and factual.
When your remediation choices involve AML or fintech-specific risk, cite FinCEN guidance to justify your approach. For consumer finance, reference CFPB supervision & examinations guidance.
If drafting examiner correspondence feels risky, engage a fractional CCO to draft and coordinate communications. That keeps executive time focused on product delivery.
Try this: Limit the narrative to a single page. Examiners appreciate clarity.
Step 3 — Remediation sprints (Weeks 6–10)
Sprint planning and sequencing with squads
Break work into two‑week sprints.
Define sprint goals tied to highest‑risk controls. Assemble cross-functional squads: one compliance owner, one engineer, one product lead, and QA.
Set a strict definition of done for each ticket: evidence artifacts, test results, and a policy or process update.
Use OWASP standards for technical acceptance criteria and OWASP Secure Development cheat sheets.
Mini example sprint:
- Sprint goal: Export KYC decision logs for sampling.
- Tasks: add export endpoint, create sampling script, update KYC policy.
- Done: export file, sample screenshots, signed policy update.
Short retro dialogue helps teams internalize what “done” means:
- QA: “We have the screenshots, but no policy excerpt in the packet.”
- Compliance: “I’ll add the excerpt and sign-off today.”
- Engineer: “Endpoint is deployed; logs are in the S3 bucket.”
Execute remediation tasks and assemble proof packets
Implement fixes in code and process.
Run unit tests, sampling tests, and peer reviews to confirm controls work. For payments, include vendor attestation items such as Stripe security and compliance docs. For each remediated control, assemble a proof packet: screenshots, log exports, signed attestations, change logs, test scripts, and the updated policy.
Use SOC 2 readiness checklist and templates to ensure you don’t miss required artifacts and a practical SOC 2 checklist. Bold the essentials in each packet’s cover note so retrieval is instant.
Continuous monitoring and verification
Stand up monitoring dashboards and alerts to show ongoing control performance. Tie alerts into an incident remediation workflow and log each spot check.
Run weekly sample audits (ten records) and log results centrally. Failures re-enter the sprint queue.
Use NIST’s detect/respond functions as a framework for monitoring. After each sprint, add a one‑paragraph summary tying tickets to proof packets. That summary becomes part of your final exam binder.
Step 4 — Checklist & mock exam (Weeks 11–13)
Finalize evidence packages and playbooks
Compile regulator-facing playbooks for each product.
Each playbook should include:
- Control mapping sheet.
- Labeled evidence folders.
- One-page narrative per product line.
Standardize file naming, versioning, and audit trails. Include third-party artifacts (AWS reports, vendor SOCs) so examiners can verify infrastructure controls.
Run a final QA checklist. Use a short ordered list like the one below to speed review:
- Each control has a proof packet.
- Artifacts are dated and versioned.
- Vendor attestations are attached.
- Policies show author and effective date.
- Mock exam questions have mapped evidence.
Your playbook should read like a clean flight checklist. Fast, consistent, and easy to follow.
Conduct a realistic mock examination
Run a 1–2 hour mock exam with internal stakeholders and, ideally, an independent reviewer. Use a scripted question set to simulate examiner pressure. Adapt mock exam script examples for realism.
Time evidence retrieval (target 24–48 hours for complex requests). Record gaps and convert them into rapid remediation tickets for a final sprint.
Blockquote a sample examiner prompt: "Show me the process and records you use to detect suspicious account activity for high-value transfers."
Short practice exchange:
- Examiner: “What triggers a manual review?”
- Team: “Threshold X and anomaly Y. Here are the last ten cases.”
- Examiner: “Where is this defined?”
- Team: “In the KYC/AML policy, Section 3.2. Ticket ABC‑123 links the latest update.”
Answer practice helps your team produce coherent, timed responses.
Pre-exam stakeholder brief and go/no-go decision
Produce a one‑page readiness memo for the CEO or board summarizing posture and outstanding items.
Define objective go/no‑go criteria:
- No outstanding high‑impact gaps.
- Mock exam complete and debriefed.
- Evidence packets retrievable within the target window.
Conclusion — Key Takeaways and Next Step
A focused 90‑day plan converts audit risk into prioritized sprint work and examiner‑ready artifacts. Small, prioritized evidence wins beat sprawling documentation.
FAQs
Q:
What’s the difference between this 90‑day plan and an annual readiness program?
A: The 90‑day plan is tactical and time‑boxed: close high‑priority gaps fast. An annual program focuses on governance maturity and continuous control testing.
Q: What minimum roles and tools do I need?
A: Minimum: compliance owner, product owner, engineer, and legal reviewer. Tools: Jira, a shared drive, Slack, and cloud compliance exports (AWS Artifact/Audit Manager if applicable).
Q: What documents do examiners request most often?
A: Common asks: policies and procedures, logs and screenshots showing control operation, vendor SOCs, signed attestations, transaction samples, and change logs. SOC readiness templates are a good practical checklist.
Q: Where can I find regulator materials and practical templates?
A: Helpful resources: FFIEC BSA/AML procedures, CFPB supervision hub, FinCEN guidance, and open checklist repos. Additional practical links: OWASP ASVS, SANS mock exam scripts, and a downloadable SOC checklist.
Good luck. Keep the plan tight and the proof packets tidy.
