Aiming for Minimum

Working within the financial sector for the last eight years has meant that I have been involved in a number of projects dealing with regulatory imperatives. Something that has always infuriated me is the desire for many organisations to deliver only the minimum necessary to achieve compliance. Don’t get me wrong I understand the dangers associated with aspirational plans and the over-engineering of ‘gold-plated’ IT developments, but the desire for minimum can be even more dangerous.

I like to compare the inception of a regulatory project with the fuelling of an aeroplane. You know where your destination is and you can work out how much fuel you need to get there, but would you ever think of fuelling the plane with the minimum amount required to get you to your destination? Imagine if you flew into difficulties, had a stronger head wind than predicted or couldn’t land at the planned airport. You would always want to have enough fuel to cover all eventualities, as the last thing you’d want to happen is to fall short (literally). However, as with aspirational projects, you don’t want to carry far too much fuel as this would cause it’s own problems. So you need to find the right balance of risk and reward.

The same goes for projects; if you decide that your destination is the closest possible place that would make you compliant and fall short then you are potentially in a heap of trouble. Likewise, should the regulator change the goalposts and increase the requirements for compliance, you could find yourself having a major re-planning exercise mid-project. So how do you find the ‘happy place’ between aspiration and falling short?

I think focusing only on the minimum is a very pessimistic, short-sighted and unambitious approach for an organisation to take. It’s fine to consider it a stop-over on your journey but please don’t make it your final destination and be sure to have enough fuel (be that budget, resource or strategic vision) to get you where you want to be. Nicola Askham recently wrote about this situation in her paper for IRM. In it she recommends taking a phased approach where the first phase should deal with achieving the foundation of compliance and subsequent phases used to build on this foundation. So again to reinforce the point, the minimum may well be part of your journey where you can stop and refuel, but it should not be your final destination. Breaking the journey into smaller steps allows you approach it in a much more manageable way and gives you natural points to reflect on where you have come from and where you are heading next. That way if you do find yourself having to replan your route, it is much more easy to do so.

One thought on “Aiming for Minimum

  1. Excellent post as ever Garry.

    When I speak (off-record) to a lot of finance companies they sit mostly in two camps:

    a) Building for the long-term, they know regulations are only going to become the norm
    b) Cobbling together the bare minimum on a wing and an (Excel) prayer

    Clearly a) is the way to go. If a company gets through FSCS SCV, Solvency II, Basel II/III or whatever, there are only more directives coming down the line and there is a huge amount of similarity between the underlying data governance, data quality, workflows, reporting and technical infrastructure involved.

    Ultimately the fines are only going to get bigger but all this is good news because I think without compliance data governance/data quality in the finance sector would still be a pipe dream for many of these firms.

    Great post, keep them coming!

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