When in doubt about whether a product, service, or activity warrants review as a new product, financial firms should err on the side of conservatism and route the proposal through the new-product approval process. Cutting short a new-product review because of a rush to deliver a new product to market, or because of performance pressures, increases the potential for serious legal and reputational risk.
The determination of whether a new or modified activity requires additional compliance processes, procedures, or controls is clearly the province of the compliance staff. It involves the interaction of business-line compliance staff with personnel responsible for enterprise-wide risk management.