been increasing rapidly over the past several years, to the delight of institutions that see these systems as solving a real problem caused by increasing expectations of regulators. But both the understanding of how these systems work and the back-testing and tuning of the many settings required to operationalize them have, in many cases, been outsourced to the vendors who supply the product. Predictably, regulators who applaud the installation of such capable technology have been highly critical of the banks' actual deployment of it. Generally, negative feedback from the regulators about the implementation of these systems has included the following complaints:
• The company is not using the full functionality of the system.
• The system is not adequately customized to align with the company's risk profile.
• The program does not capture all of the company's products and services.
• The scenarios or rules used do not adequately cover the company's risks.
• There are no statistically valid processes in place to evaluate the automated transaction monitoring system.
• There are insufficient MIS and metrics to manage and optimize the system.
More recently, the Fed has issued explicit statements that it considers such systems to be models and that therefore the requirements of SR 11-78 apply – requirements that few compliance teams or model validation teams are fully prepared to meet. Clearly, the regulatory community is quite sensitive to the fact that outsourced solutions without close internal expertise and oversight may be ineffective in achieving their goals, and in the AML area this sensitivity is backed up by firsthand experience obtained in the course of examinations. But AML is just one example. And regulators' concerns aside, the firms themselves should be very sensitive to these same issues. For any large information processing project for which a significant amount of planning, design specification, vendor selection, implementation, tuning or validation is outsourced, the ability of the firm to maximize the value of the resulting system will be compromised. If we adhere to the view that a firm's competitive advantage will derive largely from the relative effectiveness of the management of the broad range of information assets, then the outsourcing of the vision itself to a software vendor who is marketing that same vision to other institutions amounts to nothing less than a decision to make the firm less competitive.
It is not obvious how an institution should approach narrowing or eliminating the IT rift, but one thing is clear: It needs to be recognized by the senior leaders of the firm as a challenge to be overcome, and this is unlikely to occur unless corporate leaders themselves are more IT savvy than they have been historically. A more deliberate and holistic approach to information processing means not only structuring physical data processing and analytic capabilities (as discussed below), it also means creating an organizational structure to match that modernized business model (also discussed below). This means that the overall strategic direction must be identified, that the underlying physical infrastructure must be aligned with that vision, and that a plan to match personnel with that model must be developed and communicated throughout the organization. One of the principle consumers of that communication has to be the firm's human resources department, which may itself be required to take transformative steps in order to implement that strategy. The existence of dedicated IT HR departments that only hire into IT roles serves to propagate and reinforce the rift. (Interestingly, poll data from users of internal service providers within U.S. corporations found satisfaction rates for IT (MIS) and HR at 28 and 24 percent respectively9– dead last among internal providers.) If the HR function does not clearly understand the need for more strategically deployed skill sets across functions and across the revamped information processing complex, it will be impossible to implement such a strategy. This means more subject matter experts need to be embedded directly into the HR organization.
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