Spreadsheet Risks in Banks

No other industry perhaps handles such large volumes of critical financial data more than the banking industry. For decades now, spreadsheets have become permanent fixtures in the front-line reporting tool sets of banks, providing organised information when and where needed.

But as banks enter into a period of heightened credit risks, elevated levels of fraud, and greater regulatory scrutiny, many are wondering if continued reliance on spreadsheets is a wise decision for banks today.

The downfall of Lehman Brothers which eventually led to its filing for Chapter 11 bankruptcy protection on September 15, 2008, served as a wake up call for many institutions across the globe to make a serious examination of their own risk management practices. But would these reforms include evaluating the security of user developed applications (UDAs), the most common of which are spreadsheets, and putting specific guidelines as to when they can – or cannot be – used?

Banks and Spreadsheet Use

Banks have been known to utilise spreadsheets systems for many critical functions because most personnel are well-acquainted with them, and the freedom of being able to develop customised reports without needing to consult with the IT department offers flexibility and convenience. In fact, more than having a way to do financial budgeting and analysing customer profitability, even loan officers and trade managers have become reliant on spreadsheets for risk management reporting and for making underwriting decisions.

But there are more than a few drawbacks to using spreadsheets for these tasks, and the sooner bank executives realise these, the sooner they can adopt better solutions.

General Limitations

Spreadsheets are far from being data base systems and yet more often than not, they are expected to act as such, with figures constantly added and formulas edited to produce the presumably right set of reports.

In addition, data integrity is always a cause for concern as most values in spreadsheets are entered as manual inputs. Even the mere misplacement of a comma or a negative sign, or an inadvertent ?edit? to a formula can also be a source of significant changes in the outcome.

Confidentiality risk is also another drawback of the use of spreadsheets in banks as these tools do not have adequate?access controls to limit access to only authorised individuals. Pertinent financial information that fall into the wrong hands can lead to a whole new set of problems including the possibility of fraud.

Risks in Trading

For trading transactions, spreadsheets can prove to be of immense use – but only for small market volumes. As trade volumes increase and the types vary, spreadsheets are no longer a viable solution and may likely become more of a hindrance, with calculations taking longer in the face of bigger transaction amounts and growing transaction data.

And in trading, there is always the need for rigorous computational functions. Computing for the Value at Risk (VaR) for large portfolios for instance, is simply way beyond the capabilities of spreadsheets. Banks that persist in using them are increasing the risk of loss on those portfolios. Or, they can be opening up?opportunities for fraud?as Allied Irish Bank (in the case of John Rusnak – $690 million) learned the hard way.

Risks in Underwriting

Bankers who use spreadsheets as their main source of information for underwriting procedures also face certain limitations. Loan transactions require that borrowers? financial data be centralised and easily accessible to risk officers and lending officers involved in making decisions. With spreadsheets, there is no simple and secure way of doing that. Information can be pulled from different sources – individual tax returns, corporate tax documents, partnership documents, audited financial statements – hence there is difficulty in verifying that these reports adhere to underwriting policies.

Spreadsheet control and monitoring

Financial institutions which are having difficulty weaning themselves from the convenience and simplicity that spreadsheets offer are looking for possible control solutions. Essentially, they want to find ways that allow them to continue using these UDAs and yet somehow eliminate the?spreadsheet risks?and limitations involved.

Still, the debate goes back and forth on whether adequate control measures can be implemented on spreadsheets so that that the risks are mitigated. Many services have come forward to herald innovative solutions for better spreadsheet management. But at the end of the day, there really is no guarantee that such solutions would suffice.

More Spreadsheet Blogs


Spreadsheet Risks in Banks


Top 10 Disadvantages of Spreadsheets


Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry


How Internal Auditors can win the War against Spreadsheet Fraud


Spreadsheet Reporting – No Room in your company in an age of Business Intelligence


Still looking for a Way to Consolidate Excel Spreadsheets?


Disadvantages of Spreadsheets


Spreadsheet woes – ill equipped for an Agile Business Environment


Spreadsheet Fraud


Spreadsheet Woes – Limited features for easy adoption of a control framework


Spreadsheet woes – Burden in SOX Compliance and other Regulations


Spreadsheet Risk Issues


Server Application Solutions – Don’t let Spreadsheets hold your Business back


Why Spreadsheets can send the pillars of Solvency II crashing down

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What GDPR Means in Practice for Irish Business

The General Data Protection Regulation (GDPR) is a European directive aimed at ring-fencing consumer data against illegal or unnecessary access. There is nothing to discuss or debate with local politicians, or the Irish Data Protection Commissioner for that matter. As a European directive, it has over-riding power. To obtain an English version, please visit this link, and select ?EN? from the table of languages.

As you reach for your tea, coffee or Guinness after sighting it, you will be glad to know the Irish Data Protection Commissioner has the lead in turning this into business English we understand. The following diagram should assist you to obtain a quick overview of the process we all have to go through. In this article, we briefly describe what is inside Boxes 1 to 12. The regulation comes into force on 25 May 2018 so we have less than a year to get ready.

The 12 Essential Steps to Implementing the General Data Protection Act

1. Create awareness among your people of what is coming their way. The GDPR has given our regulator discretion to dish out fines up to ?20,000,000 (or 4% of total annual global turnover, whichever is greater) so there is determination to make this happen.

2. Become accountable by understanding the consumer data you hold. Why are you retaining it, how did you obtain it, and why did you originally collect it. Now you know it is there, how much longer will you still need it? How secure is it in your hands, have you ever shared it?

3. Open a communication channel with your staff, your customers, and anyone else using the data. Share how you feel about how accountable you have been with the information in the past. Explain how you plan to comply with the GDPR in future, and what needs to change.

4. Understand the personal privacy entitlement of the subjects of the information. They have rights to access it, correct mistakes, remove information, restrict its use, decline direct marketing, and copy it to their own files. What needs to change in your systems to assure these rights?

5. Issue a policy for allowing consumers access to their information you hold. You must process requests within a month, and you may not charge for the service unless your cost is excessive. You may decline unfounded or excessive demands within your policy guidelines.

6. Adapt to the requirement that you must have a legal basis for everything you do with, and to consumer data. You need to be in a position to justify your actions to the Irish Data Protection Commissioner in the event of a complaint. Having a legitimate interest is no longer sufficient.

7. Ensure that consumer consent to collect, use, and distribute their data is ?freely given, specific, informed, and unambiguous.? From 25 May 2018 onward, this consent will be your only ground to do so. You cannot force consent. Your benchmark becomes what the GDPR says.

8. Issue rules for managing data of underage subjects. This is currently under review and we are awaiting results. Put systems in place to verify age. Set triggers for where guardians must give consent. Make sure age is verifiable. Use language young people understand.

9. Introduce a culture of openness and honesty, whereby breaches of the GDPR are detected, reported, investigated, and resolved. You will have a duty to file a GDPR report with the Data Protection Commissioner within 72 hours, thus it is important to fast track the process.

10. Introduce a policy of conducting a privacy assessment before taking new initiatives. The GDPR calls for ?privacy by deign?, and we need to engineer it in. This may be the right time to appoint a data controller in your company, and start implementing the GDPR while you have time.

11. You may also need to appoint a data protection officer depending on the size of your business. Alternatively, you need to add managing data protection compliance to an employee?s duties, or appoint an external data-protection compliance consultant.

12. Finally, and you will be glad to know this is the end of the list, the GDPR has an international flavour in that multinational organisations will report into the EU Lead Supervisory Authority. This will manage the process centrally while consulting national data authorities.

The GDPR is a project we all need to complete. If we are out of line, it is in our interests to get things straightened out. Once everything is in place, the task should not be too onerous. Getting there could be the pain.

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Maturing Into CMMI

 

In all likelihood, the reason why you landed on this page was because you were seeking CMMI experts to help you meet the demands of a growing number of potential clients who require CMMI compliance.

Whether or not you’re here for that reason, you might want to know why CMMI or Capability Maturity Model Integration is steadily becoming a common denominator among highly successful software and engineering development companies. If you stay for a while, we can show you how CMMI can substantially increase your organisation’s chances of:

  • reducing development costs;
  • acquiring new customers and retaining old ones;
  • beating deadlines;
  • bringing down development time;
  • increasing the overall quality of your products and services; and
  • improving the level of satisfaction of customers, employees, and all other stakeholders.

Surely, no organisation can be too small or too big to aspire for such benefits of attaining high levels of maturity and capability.

If you want to look beyond Maturity Level ratings, then you’ve come to the right place. We focus on introducing CMMI principles and blending them into your organisation’s culture to achieve a truly superior and sustainable business advantage. Compliance will then be an inevitable offshoot of the actions you make.

Likewise, if you simply want to obtain a deeper understanding of CMMI and learn how it can be applied either to your entire organisation or to specific projects, we’d be happy to assist you in that regard as well.

Finally, when you’re ready, we can also conduct CMMI appraisals either for benchmarking purposes or simply for determining how well your process improvement initiatives are going.

CMMI Consulting

Are you worried that implementing CMMI might entail an overhaul of your current processes? Don’t be.

CMMI is all about improving current processes, not replacing them. Ideally, the final result of all process improvement activities should be hinged on your own business objectives and context, so we’ll make sure it remains that way when we work with you.

We rely on our extensive knowledge and experience in CMMI, engineering, software development, and technologies as well as in change and project management in providing model-based process improvement services. Whether you’re gearing up for an appraisal or simply want to employ CMMI-based practices, these are the things we can do for you.

  • Help you interpret how CMMI can be implemented in relation to your business.
  • Assist in convincing sponsors and stakeholders to support your CMMI implementation initiatives.
  • Introduce the necessary training to all individuals who need to undertake them.
  • Conduct a Gap Analysis to find out where your company’s current processes stand relative to their CMMI specifications.
  • Assemble a process group that will champion your process improvement initiatives. We’ll facilitate effective collaboration among its team members, transforming them into a cohesive force designed to carry out plans and motivate everyone else down the line.
  • Introduce tools and practices that will improve the efficiency of our process improvement initiatives.
  • Carry out periodic evaluations and produce reports to provide sponsors and stakeholders a clear picture of our progress.

CMMI Training

Still not convinced CMMI is right for you? There’s only one way to fully grasp the benefits of implementing CMMI – take the Introduction to CMMI course. Although what happens next is entirely up to you, we’re pretty sure you’ll make the right decision after passing it.

Do you need to include people from your organisation in a SCAMPI (Standard CMMI Appraisal Method for Process Improvement) team? They’ll have to undergo this course too. The Introduction to CMMI is for systems and software engineering managers and practitioners, appraisal team members, process group members, and basically anyone who want to grasp CMMI fundamentals.

This is what you’ll be able to do after going through 3 days of lectures and exercises:

  • Gain a deeper understanding of the various components of CMMI-DEV models and their relationships.
  • Discuss the process areas in CMMI-DEV models.
  • Extract and interpret aspects in the model relevant to your own organisation’s processes.

We also offer highly specialised training and workshops such as those for:

  • Achieving High Maturity Levels
  • Top Executives
  • Team Building in Preparation for Appraisals

CMMI Appraisal

An organisation new to CMMI will want to know first how far their current processes are relative to the implementation of model-based improvements in order to determine the resources and time that have to be spent to get there.

Similarly, an organisation already well acquainted with CMMI and has begun taking steps in improving processes, will eventually want to know how close it has come to the Maturity Level it has aimed for.

In both cases, these organisations will have to be assessed by a qualified CMMI appraiser to obtain an accurate picture of their current status. We can perform appraisals on either your entire organisation or on specific projects/practices within a process area. Our appraisers can conduct the following SCAMPI (Standard CMMI Appraisal Method for Process Improvement) appraisals:

  • SCAMPI Class A – This is what you’ll need if you’re aiming for a level rating.
  • SCAMPI Class B – You may want to use this for process reviews or for preparing for a SCAMPI Class A.
  • SCAMPI Class C or Gap Analysis – We typically conduct this for organisations who have yet to implement CMMI-based initiatives so that they can design the most cost-effective road map for the implementation proper.
Why Executives Fail & How to Avoid It

The ?Peter Principle? concerning why managers fail derives from a broader theory that anything that works under progressively more demanding circumstances will eventually reach its breaking point and fail. The Spanish philosopher Jos? Ortega y Gasset, who was decidedly anti-establishment added, “All public employees should be demoted to their immediately lower level, as they have been promoted until turning incompetent”.

The Peter Principle is an observation, not a panacea for avoiding it. In his book The Peter Principle Laurence J. Peter observes, “In a hierarchy every employee tends to rise to his level of incompetence … in time every post tends to be occupied by an employee who is incompetent to carry out its duties … Work is accomplished by those employees who have not yet reached their level of incompetence.”

Let’s find out what the drivers are behind a phenomenon that may be costing the economy grievously, what the warning signs are and how to try to avoid getting into the mess in the first place.

Drivers Supporting the Peter Principle

As early as 2009 Eva Rykrsmith made a valuable contribution in her blog 10 Reasons for Executive Failure when she observed that ?derailed executives? often find themselves facing similar problems following promotion to the next level:

The Two Precursors

  • They fail to establish effective relationships with their new peer group. This could be because the new member, the existing group, or both, are unable to adapt to the new arrangement.
  • They fail to build, and lead their own team. This could again be because they or their subordinates are unable to adapt to the new situation. There may be people in the team who thought the promotion was theirs.

The Two Outcomes

  • They are unable to adapt to the transition. They find themselves isolated from support groups that would otherwise have sustained them in their new role. Stress may cause errors of judgement and ineffective collaboration.
  • They fail to meet business objectives,?but blame their mediocre performance on critical touch points in the organization. They are unable to face reality. Either they resign, or they face constructive dismissal.

The Warning Signs of Failure

Eva Rykrsmith suggests a number of indicators that an individual is not coping with their demanding new role. Early signs may include:

  • Lagging energy and enthusiasm as if something deflated their ego
  • No clear vision to give to subordinates, a hands-off management style
  • Poor decision-making due to isolation from their teams? ideas and knowledge
  • A state akin to depression and acceptance of own mediocre performance

How to Avoid a ?Peter? in Your Organization

  • Use succession planning to identify and nurture people to fill key leadership roles in the future. Allocate them challenging projects, put them in think tanks with senior employees, find mentors for them, and provide management training early on. When their own manager is away, appoint them in an acting role. Ask for feedback from all concerned. If this is not positive, perhaps you are looking at an exceptional specialist, and not a manager, after all.
  • Consider the future, and not the past when interviewing for a senior management position. Ask about their vision for their part of the organization. How would they go about achieving it? What would the roles be of their subordinates in this? Ask yourself one very simple question; do they look like an executive, or are you thinking of rewarding loyalty.
  • How to Avoid Becoming a ?Peter??Perhaps you are considering an offer of promotion, or applying for an executive job. Becoming a ?Peter? at a senior level is an uncomfortable experience. It has cost the careers of many senior executives dearly. We all have our level of competence where we enjoy performing well. It would be pity to let blind ambition rob us of this, without asking thoughtful questions first. Executives fail when they over-reach themselves, it is not a matter of bad luck.

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