Not only is that true, it's usually not even the regulators that are making up the final actionable items. Businesses hire independent auditors who need to make

Not only is that true, it's usually not even the regulators that are making up the final actionable items. Businesses hire independent auditors who need to make sure their clients are well clear of what the regulators would be concerned with, and so push them to go even farther. And of course, once you have passed one audit, the next year's audit will be even more strict, even if the regulations themselves have not changed. The auditors do need to justify their own employment, after all.