kri-commentary

Drafts second-line commentary on KRI / KCI movement and breaches for a periodic risk report. Each per-KRI block carries trend, breach status against the firm's risk appetite statement, named root cause and contributing factors, action taken and action planned with role-level owners and dates, residual-risk view, linked issues and material events, and an explicit second-line challenge note where the second-line view diverges from first-line. Output is a per-KRI commentary block ready to drop into the risk committee pack, the divisional risk pack, the regulator response, or the board memo after qualified review.