Attached files
| file | filename |
|---|---|
| EX-99.1 - EX-99.1 - LendingClub Corp | d173418dex991.htm |
| EX-99.2 - EX-99.2 - LendingClub Corp | d173418dex992.htm |
| 8-K - 8-K - LendingClub Corp | d173418d8k.htm |
Exhibit 99.3
Lending Club’s Data Management Remediation Plan
In the immediate term, Lending Club is making the following enhancements:
| Area of Focus | Planned Activities | |
| Ability to change data fields inappropriately |
• Enhancing the testing of data changes prior to deployment based on the risk of the change
• Reviewing change requests for key data attributes, prior to implementation, by the Internal Audit Team
• Validating that change requests for key data attributes have been properly executed
• Expanding the number of data fields that are logged for changes
• Monitoring logs for key changes
• Refreshing training/communication on data change management processes
• Enhancing the end-to-end testing framework
• Completing a consulting engagement on data change management with a Big Four accounting firm; implementing appropriate best practices
| |
| Code of conduct and ethics of personnel involved in change process |
• Retraining employees on code of conduct and ethics and the whistleblower hotline
• Reinforcing a high compliance culture as explicit objectives in the employee performance review process |
