LITIGATION AND OTHER LEGAL MATTERS – PROCESS WORKFLOW (SAMPLE)

Step 1 – Receipt of complaint or legal document (Garnishment, Subpoena, Summons/Complaint)•Regulator•Vendor•Unrelated third party• Internal/ Employee•Customer

Step 2 – Evaluate & Notify• If telephonic or in-person complaint, attempt to resolve promptly

•Document / Report (date, time, persons involved, your name, action taken)

•Elevate to Management & Legal

Step 3 – Refer to Legal

•Material or threat of litigation•Not immediately resolved•Summons & Complaint, Subpoena, Garnishment, Levy, or other legal document

Step 4 – Legal Evaluation•File insurance claim (Notify Corporate Ins)

•Retain Outside Counsel•Review written response to Customer, Regulator, Employee

• Issue Litigation Hold Notice to Business or Operational Unit, and Security, IT, HR, as appropriate

Step 5 – Monitor to Resolution•Preserve and or gather relevant documentation (electronic & paper)

•Review for privilege and or redact confidential information

•Report monthly or quarterly on progress towards resolution

Step 6 – Report Post-Resolution•Operational losses to ERM and business or operational unit

•Policy or procedural violation to Compliance and Internal Audit, as appropriate

•Recommend “good practice” (e.g. “lesson learned”) to business or operational unit re policies, procedures or training to avoid or mitigate future losses, complaints or litigation