Blog · Coverage and territory · Compliance
The complete obligation-to-control coverage calculation on ten obligations, small enough to check by hand: each obligation's rating and business unit from the register, the controls mapped to it, the control's testing frequency and last test date, whether the control is on cadence, the obligation's state, covered by a control on cadence, covered by a slipped control, mapped to a retired control, or unmapped, coverage by unit and by rating, the change backlog for the two obligations from this year's regulatory changes, and the assertion that the states sum to ten, so a reader can reproduce every figure and then run it on their own registers.
Obligation coverage is a join of the obligation register to the control register and a state per obligation, and on ten obligations it can be worked by hand. This page works the mapping, the cadence check, the states, coverage by unit and rating, the change backlog and the assertion. Today: 17 September 2026. Tolerance: 10 days.
Obligations:
| Obligation | Unit | Rating | Effective | Mapped controls |
|---|---|---|---|---|
| O-1 | Payments | High | 2019 | C-1 |
| O-2 | Payments | Medium | 2019 | C-2, C-3 |
| O-3 | Payments | High | 2024 | C-4 |
| O-4 | Payments | Low | 2019 | none |
| O-5 | Payments | Medium | 30 Apr 2026: change | none; in progress, owner set, target 30 Sep |
| O-6 | Lending | High | 2019 | C-5, C-6 |
| O-7 | Lending | Medium | 2019 | C-7 |
| O-8 | Lending | Low | 2019 | C-8 |
| O-9 | Lending | Medium | 2019 | C-9 |
| O-10 | Lending | Low | 19 Feb 2026: change | none; no owner |
Controls:
| Control | Frequency | Last test | Status |
|---|---|---|---|
| C-1 | Quarterly (90 days) | 20 Jun 2026 | Active |
| C-2 | Monthly (30) | 5 Sep 2026 | Active |
| C-3 | Quarterly | 2 Mar 2026 | Active |
| C-4 | Quarterly | 15 Jan 2026 | Retired 31 Mar 2026 |
| C-5 | Monthly | 1 Sep 2026 | Active |
| C-6 | Annual (365) | 10 Nov 2025 | Active |
| C-7 | Quarterly | 1 May 2026 | Active |
| C-8 | Annual | 3 Aug 2026 | Active |
| C-9 | Quarterly | 12 Jul 2026 | Active |
On cadence if days since last test ≤ frequency + 10
| Control | Days since test | Limit | On cadence? |
|---|---|---|---|
| C-1 | 89 | 100 | Yes |
| C-2 | 12 | 40 | Yes |
| C-3 | 199 | 100 | No: slipped |
| C-4 | retired | Not a control | |
| C-5 | 16 | 40 | Yes |
| C-6 | 311 | 375 | Yes |
| C-7 | 139 | 100 | No: slipped |
| C-8 | 45 | 375 | Yes |
| C-9 | 67 | 100 | Yes |
| Obligation | Controls on cadence | State |
|---|---|---|
| O-1 | C-1 | Covered |
| O-2 | C-2 (C-3 slipped) | Covered |
| O-3 | none: C-4 retired | Unmapped in fact: mapped to a retired control |
| O-4 | none | Unmapped |
| O-5 | none; in progress, target 30 Sep | In progress |
| O-6 | C-5, C-6 | Covered |
| O-7 | none: C-7 slipped | Covered by a slipped control only |
| O-8 | C-8 | Covered |
| O-9 | C-9 | Covered |
| O-10 | none; no owner | Unmapped |
obligations = covered + covered by slipped only + in progress + unmapped = 6 + 1 + 1 + 2 = 10
| Cut | Obligations | Covered | Coverage |
|---|---|---|---|
| Payments | 5 | 2 (O-1, O-2) | 40% |
| Lending | 5 | 4 (O-6, O-8, O-9; O-7 slipped-only) | 80% |
| High-rated | 3 | 2 (O-1, O-6) | 67%: O-3 uncovered |
| All | 10 | 6 | 60% |
| Obligation | Effective | Days uncovered | Owner | Target |
|---|---|---|---|---|
| O-5 | 30 Apr | 140 | Yes | 30 Sep: 13 days |
| O-10 | 19 Feb | 210 | None | None |
Retired control counted. O-3 reads covered; Payments reads 60 percent; the high-rated gap disappears.
Slipped controls counted. O-7 reads covered with a control last tested in May.
Rating split skipped. Sixty percent overall; the uncovered high-rated obligation invisible.
Change log not joined. O-10 was never created in the register at all.
The same join, cadence check and state per obligation, by unit and rating, every month. Covirage runs it on the obligation, control and change registers. The obligation coverage guide covers the measure, and the testing cadence guide covers the control side.
Because a control that no longer runs covers nothing. The register still shows the link, which is how the obligation looks covered on paper. The control register's retirement date is joined, and the obligation moves to unmapped with the reason.
Stated: ten days here. A quarterly control tested within 100 days of its last test is on cadence; at 101 it has slipped. An obligation whose only control has slipped is covered by a control nobody has checked recently, and that is its own state.
Two of three high-rated obligations covered. The one that is not, O-3, is the regulator's first question. Coverage by count across all ten hides it; the rating split shows it.