The report addressed weaknesses of the Financial Conduct Authority's IT systems which it has inherited from the FSA, and consideration of a common utility platform for core banking services, but Intellect believes it should have gone further in making technology infrastructure one of its core issues, in particular:
- Consideration of a greater number of technology-literate individuals in decision-making positions on boards
- Encouraging banks to more comprehensively map their existing systems and processes – which should have been done as part of ongoing recovery and resolution requirements. If this is undertaken, change can be implemented more quickly and with reduced cost; weaknesses and risks can be better identified before they impact customers; and decisions on issues such as branch divestures can be made with greater certainty
- Clarification from regulatory authorities on what they want banks to be able to do in the future and allow banks to work towards this, without wasting money on duplicative regulatory implementation
- Facilitating a greater degree of collaboration across banks, to identify how common problems of technology infrastructure – outlined comprehensively in the Commission's paper - can be addressed more systematically and effectively
'Many of these issues around conduct, competition and supervision have a common denominator – the technology infrastructures that facilitate all the operations of the bank,' said Ben Wilson, Associate Director for Financial Services Programmes at Intellect.
You reduce the complexity of this, and you ultimately make life a lot easier for the banks and the regulators, and you improve the ability of the banks to serve the customers and the wider economy'