Federal Reserve Board issues enforcement action with former employee of PrimeLending

When a terminated employee continues to originate loans or interact with borrowers, the failure sits in the access-revocation decision that was either never made, never recorded, or never verified. A termination checklist is not a decision record; compliance needed a structured artifact naming who approved the original access grant, who owned the revocation trigger, and what review cadence confirmed closure. The general lesson is that employee lifecycle decisions—hire, promote, grant authority, revoke access—demand the same engineering rigor as credit approvals, with ownership and periodic reconciliation baked in at the moment of separation.