As we noted in our recent ‘Brexit’ blog, the need for managing cross-border complexity in the Client On-boarding and Lifecycle management domain now, more than ever, requires software that can provide flexible workflow and readily configurable rules.  In case we have been distracted by the present focus on Brexit in recent months, let’s not forget that MiFID II, EMIR, Dodd Frank, General Data Protection regulation etc., continue to exert pressure on our client on-boarding, KYC and AML due diligence processes.

As previously discussed, the complex, cross-functional processes covering Front Office, Middle Office, Compliance and Back Office, across many jurisdictions often results in a number of negative outcomes for firms:

-         Repeated requests for client data

-         Manual sourcing and processing of information

-         Disproportionate amounts of time spent on low risk data

-         Inconsistently applied compliance policies

-         Siloed approaches to multiple regulations

-         Inability to adapt quickly and cost-efficiently to regulatory changes

-         Disjointed processes traversing disparate systems

-         Data errors

In this context, and with the very real need for financial firms to be able to adapt to changes in the regulatory landscape easily, the last thing any software provider in this space should be offering is a black box system.  A black box is a system which can be deployed and utilised on the basis of inputs and outputs without any knowledge of, or access to its internal workings or code base.  Its implementation is opaque to the end user at best, or completely impenetrable at worst.

Sadly, in the Client Lifecycle Management (CLM) space, many vendors [through use of legacy systems and/or redundant architecture] continue to sell and implement what are effectively black box systems. This leaves their clients subject to slow and costly implementation times, with a lack of agility in deploying changes. Consequently, they are open to the risk of serious regulatory chastisement or fining for procedural, rule application or data quality non-compliance.

In direct contrast, there are specifically designed platforms that will, through their ability to be easily configured by internal teams, transform the way firms are able to respond to ongoing regulatory change and rules refinement.  These systems can adapt to changing rules and processes, not the other way round, where processes have to change to fit with the system design, which is the case with black box systems.

With a configurable platform, staff are empowered to create flows and rules that reflect how their work actually needs to be performed, rather than conform to a technology firm’s idea of how it should work or be implemented.  And what does this mean in practice? The control of rules configuration is put into the hands of a firm’s experienced teams – those who know best how things should be configured!

In the very same way that the song “Consider Yourself” from the 1960s musical ‘Oliver!’ conveys a sincere gift of friendship from Dodger and his gang to Oliver; assuring him warmly that he can consider himself “our mate” and “one of the family,” as “it’s clear we’re going to get along,” – we like to think that the future-thinking design of a configurable CLM platform will allow a firm to “configure it yourself and consider yourself one of us!”