About TGC³ Advisory: From Enterprise Identity Governance to Specialized Consulting
TGC³ Advisory emerged from years of designing and implementing identity governance frameworks, privileged access controls, and RBAC models in highly regulated financial services environments—from Fortune 500 banks to newly chartered institutions navigating first-time OCC examinations.
- Executive leadership expertise from former security governance and identity leaders
- Enterprise RBAC transformations covering tens of thousands of identities
- Privileged access governance program implementations
- ICFR/ITGC logical access remediation programs (multi-year audit findings to closure)
- OCC examination support and FFIEC assessment response coordination
- Board and audit committee governance reporting with executive risk narratives
What became clear across every engagement: Governance failures in financial services aren't caused by missing policies—they're caused by missing mechanisms.
Organizations invest heavily in policy libraries, governance committees, and documentation frameworks. Yet when OCC examiners arrive, when FFIEC assessments begin, or when SOX 404(b) auditors test logical access controls, the evidence doesn't exist. Joiner/mover/leaver processes executed inconsistently. Privileged access approvals weren't documented. Role assignments lacked business justification. Access certifications ran sporadically—or not at all.
TGC³ Advisory exists to build the systematic mechanisms that make governance real: identity lifecycle automation, RBAC models with clear ownership, privileged access boundaries with approval workflows, and evidence loops that capture control effectiveness continuously.
TGC³ Advisory is a specialized governance consulting firm that helps financial services organizations build exam-ready identity governance frameworks, RBAC models, privileged access management systems, and AI governance controls. Founded on mechanism design principles, TGC³ Advisory focuses on systematic control implementation—not policy documentation—to help banks, credit unions, and financial institutions pass OCC examinations, FFIEC assessments, and SOX 404(b) audits.
- Identity governance maturity assessment and remediation
- RBAC model design and implementation
- Privileged access management (PAM) governance frameworks
- ICFR/ITGC logical access control remediation
- AI governance through identity-based access controls
- Evidence loop automation for continuous audit readiness
- Board and audit committee governance reporting
TGC³ Advisory's Core Governance Principles
H3: Governance is Mechanism Design, Not Policy Creation
Effective identity governance in financial services requires systematic control mechanisms—not aspirational policy statements. A policy that requires "role-based access control" is meaningless without role design standards, assignment procedures, approval workflows, and periodic recertification processes that actually execute.
TGC³ Advisory builds the mechanisms that make governance operational: identity lifecycle automation, RBAC models with defined roles and ownership, PAM frameworks that enforce privileged access boundaries, and evidence loops that capture control effectiveness automatically. These aren't theoretical frameworks—they're executable control systems that operate consistently.
H3: Evidence Must Be Continuous, Not Scrambled Before Audits
Examination readiness comes from governance systems that generate defensible evidence as a natural byproduct of operations—not from documentation sprints when auditors arrive.
When identity lifecycle processes execute, they should log authoritative data proving joiner/mover/leaver controls work. When privileged access requests are approved, approval chains should be captured automatically. When access certifications run, evidence should be timestamped and auditable. When role assignments change, business justification should be documented at decision point.
TGC³ Advisory designs evidence loops—not evidence scrambles—so that by the time OCC examiners or SOX auditors arrive, the evidence already exists in examination-ready format.
H3: AI Governance is an Identity and Access Management Problem
AI governance frameworks built solely on model-centric policies fail under regulatory scrutiny. Policies stating "AI shall be used responsibly" or "high-risk models shall be documented" provide no operational control and generate no evidence.
TGC³ Advisory reframes AI governance through identity and access management: Who can access what AI systems? For what purposes? With what oversight? This leverages the same systematic IAM frameworks that financial services auditors and examiners already understand and trust.
The TGC³ Advisory approach to AI governance:
Treat AI system access like privileged system access
Define roles based on user sophistication and use case sensitivity
Implement approval workflows for elevated AI capabilities
Monitor usage patterns and flag anomalies
Generate evidence proving AI governance controls execute
Result: AI governance frameworks that integrate with existing identity controls and satisfy examiners who understand access management better than model risk.
H3: Deliver Big 4 Quality with Specialized Expertise
TGC³ Advisory delivers the documentation rigor, systematic frameworks, and professional quality standards expected from major consulting firms (Deloitte, KPMG, PwC, EY)—but with deep specialization in identity governance, logical access controls, and exam-ready systems for financial services.
Deliverables follow the same structure that Big 4 firms use: maturity assessments with heatmaps, governance frameworks with clear ownership, evidence packages for auditor review, board presentations with executive summaries. The difference: TGC³ Advisory brings specialized expertise in identity governance mechanisms that generalist consultants lack.
