Where to focus next

Review actual vendor evaluation obstacles against the two proposed guidance documents.

Relevant function

Product, commercial and policy leadership

Output

One documented obstacle and a decision on whether any engagement is useful.

Timing

Before November 16, 2026, if the listed deadline remains unchanged.

The comment deadline is an opportunity, not a requirement to comment. Recheck the official pages first.

• Watch for friction in due diligence, contracting, model review and data access requirements when institutions evaluate a provider.

Review real vendor evaluation friction against OP-1881 and OP-1880 before the listed comment deadline.

Relevant function

Product, commercial and policy leadership

Output

A documented friction list mapped to the proposal text, and a decision on whether engagement is warranted.

Timing

Before November 16, 2026, if the official deadline remains unchanged.

Recheck the official pages first. A requested deadline extension is not an approved extension.

• Watch for friction in due diligence, contracting, model review and data access requirements during bank evaluations.

Review how BayCom's actual outcomes compare with the assumptions behind the repositioning.

Relevant function

Commercial lead with a finance or treasury counterpart

Output

A confirmed planning need, or a decision to move on.

Timing

No fixed date. Establish relevance before any proposal.

• Watch how actual earnings, funding costs and portfolio outcomes compare with the assumptions behind the repositioning.

Understand which combined plan assumption is hardest to reconcile at PenAir and Fort McClellan.

Relevant function

Commercial lead with a finance or integration counterpart

Output

A bounded use case, or a decision that the fit is limited.

Timing

No fixed date. Merger remains conditional.

• Watch where the institutions' assumptions about deposits, loans, funding and integration timing differ most.

Confirm Hedgehog's product fit before using capability claims in a customer conversation.

Relevant function

Product or solutions team

Output

An approved capability mapping. Not a claim of partnership.

Timing

Before any capability statement is used externally.

• Confirm which of these use cases the product supports today and how that should be described.

Confirm CBLR eligibility and election before using the 8 percent rule in a customer conversation.

Relevant function

Commercial lead with a finance or treasury counterpart

Output

A confirmed eligible and electing institution, or a decision to drop the CBLR angle.

Timing

Before the CBLR change is referenced in any customer conversation.

The framework is optional and conditional. Asset size alone does not establish eligibility or election.

• Watch how the 8 percent CBLR threshold changes capital buffer, growth and funding thinking over the next four quarters.

Assess whether the SB 1075 fee cap materially changed earnings, deposit, funding or balance sheet assumptions at a specific state chartered credit union.

Relevant function

Commercial lead with a finance or treasury counterpart

Output

Material planning impact confirmed, or set aside if the effect is immaterial.

Timing

Before SB 1075 is referenced in any customer conversation.

The cap applies to California credit unions subject to the statute. Charter and applicability are not assumed.

• Watch how the $14 overdraft cap changes assumptions about deposit product economics, noninterest income and funding strategy.

Use the Texas merger framework only when a live transaction creates a real assumption reconciliation question.

Relevant function

Commercial lead with a finance or integration counterpart

Output

A bounded merger planning use case, or a decision that the fit is limited.

Timing

Only when a live transaction creates a real assumption reconciliation question. No fixed due date.

Lead case: Alamo City → TAP. Application is not approval or completion.

• Watch which capital, credit loss, deposit and funding assumptions change most when Alamo City is modeled inside TAP's surviving balance sheet.

Assess whether the combined Wings institution has a meaningful workflow for comparing expected results with actual results, or an integration planning workflow, that sits outside the selected core platform implementation.

Relevant function

Commercial lead with a finance or integration counterpart

Output

A complementary analytics use case, or a decision that the fit is limited.

Timing

No fixed due date. Establish relevance before any product proposal.

KeyStone is the selected core platform. Any Hedgehog role would be complementary; this does not involve replacing that platform.

• Watch how actual combined funding, deposit, loan, capital and operating results compare with the assumptions used in the merger and integration plan.

Recheck docket deadlines, merger milestones and later earnings releases.

Relevant function

Analyst

Output

Updated records when an official publication or status changes.

Timing

Trigger: new official publication or status change.

Analyst-maintained updates only. No automated monitoring is enabled.

Track the credit union lending reform bills for real legislative movement.

Relevant function

Analyst

Output

Updated records if the bills see committee or floor action, inclusion in a moving vehicle, or enactment.

Timing

Trigger: committee or floor action, inclusion in a moving legislative vehicle, or enactment.

Pending legislation. Advocacy for inclusion in end of year or defense legislation is not proof that enactment is likely.

• If lending authority expands, watch which part of the balance sheet institutions re-test first.
• Watch how a longer permissible loan term would change duration, funding and earnings assumptions.

Track Central Liquidity Facility legislation only for relevant credit union segments.

Relevant function

Analyst

Output

Updated records if S. 3575 advances, flagged only for institutions using or considering CLF access.

Timing

Trigger: committee or floor action, inclusion in a moving vehicle, or enactment.

• Watch whether a change in CLF access would materially alter contingency funding assumptions, or whether another liquidity source remains more important.

Recheck the third party risk proposals for finalization or change.

Relevant function

Analyst

Output

Updated records if the proposals are finalized, changed or the comment deadline moves.

Timing

Trigger: finalization, revision or a deadline change on the official pages.

Both documents are proposed, not final, and do not themselves create enforceable standards.

Track DFPI guidance and enforcement under SB 825 for developments that materially affect product pricing or fee assumptions.

Relevant function

Analyst

Output

Updated records if DFPI action clarifies application to a defined bank or credit union product.

Timing

Trigger: material DFPI enforcement, rulemaking or guidance.

• Watch whether California product pricing or fee assumptions are revisited under the broader DFPI enforcement posture.