Hoffer includes Charlotte, N.C.-based FRS' RiskResolve operational risk management solution among the key technologies the bank relies on for compliance. UBOC began using RiskResolve in early 2005 for Sarbanes-Oxley compliance when the institution decided its proprietary solution wasn't cutting it, he relates. "We did start producing a custom solution," Hoffer says. "It was intended to be quick and dirty, and, unfortunately, that's what it was. It solved the problems at the time, but as our business was changing and as it became clearer to us exactly what we needed to do in the long term, we realized the tool wasn't going to work."
In searching for a solution, UBOC wanted a tool that would document risk, controls and testing, and fit in with its existing technology environment without introducing new database management software or new operating systems, according to Hoffer, who says the system has garnered mixed reviews. "It definitely allowed us to meet the regulations" he comments, adding that it gave those within the bank a better understanding of the risk they face and the controls in place. But, Hoffer notes, the solution is "not as intuitive as we would like," and getting the hang of the solution has posed some challenges.
In addition to user adoption, another major barrier to implementing an integrated compliance solution is building a common data set, according to SunGard's Nosal. While a lot of businesses within the bank may have their own underlying data models -- and may be reluctant to give up ownership of their data -- for an enterprisewide risk and compliance platform to succeed, it is critical that data silos be merged into a clean, centralized data repository, Nosal says.
"All banks struggle with this data problem, and, frankly, they probably always will," says Tom Day, SunGard's SVP of products and engineering. Until the boards of banks make the decision to integrate culturally, he says, it's hard to get the applications to work together.
While integrating existing data can be among the greatest challenges to achieving an enterprisewide compliance platform, there are steps that can be taken to make the process smoother going forward. For example, a common on-boarding system is key to having one customer ID across all business lines, notes Commerce Bank's Gertie. "Good technology on the front end makes our job a lot easier," he says.
According to Gertie, consolidated platforms are helpful in doing enterprisewide analysis and reporting. For example, Commerce Bank installed a "soup to nuts" mortgage processing system about a year and a half ago, he says. Instead of having a loan origination system, a processing system and a booking system, the functionality all is merged into one solution -- Integra's (Franklin, Tenn.) Destiny loan origination system. "This system has allowed us to streamline and really improve our compliance prospects in the mortgage area because there are no data entry errors or inconsistency in the data as it flows through the process," Gertie explains.