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Regulatory change in Banking

Client Requirement

The Dubai based arm of an International Bank needed a Change Manager to guide the implementation of a Central Bank mandated Image Cheque system.

The role consisted of managing internal resources to accommodate the change in systems and process, as well as co-ordination of external vendor and liaison with the Regulator’s project team.

The project encompassed all aspects of introducing this ground breaking software into the company.

The Regulator had chosen its preferred supplier of software and was basing its new environment on what the software was capable of. A key consideration was the relative progress of the 51 other implementing institutions across the Emirate, as the system as a whole would pass or fail based on compliance from each participant in the clearing system.

Additionally there were concerns surrounding the legal standing of adopting an imaging based payment system. Finally the bank’s clearing team were also required to familiarise themselves with the technology and process during a series of parallel runs; effectively doubling their workload on selected days.

A governance structure comprising of; Steering committee (Department heads), Working group (Nominated SMEs) and the core project team (staffed with implementers and the Clearing team), was created.

With the absence of a fixed implementation deadline a critical path of activities requiring completion prior to going live was drawn up. Each of the three groups described above were given an issue or task to focus on. The Steering committee was concerned with competitor readiness and legal concerns. Working group with designing processes and understanding policy changes. And the Project team with testing and integration of the system into the IT environment.

Aside from the ambitious nature of the change, the maturity of the banking system in the Middle East etc. There were a number of challenges that were address during the project:

  1. Lack of a fixed implementation date: The Regulator insisted on setting unrealistic deadline dates which would move out the week prior to the proposed go live date
  2. Legal standing of Imaged cheques: As mentioned, throughout the lead up to the implementation date there were no indications from the Government that legal issues would be resolved prior to going live
  3. Parallel run testing: Significant increase in volume required to be processed with the same resource, alongside the need to balance the live work against the testing volume.

The Steering committee engaged their external networks to gain supporters across the banking community, resulting in a meeting of 26 of the top influencers in the industry at a local hotel. From this coalition a delegate was sent to negotiate a firm delivery date and assurances that the legal situation would be resolved prior to implementation. In addition with these actions, and through the project, the bank introduced new imaging secure cheques into operation.

  • Through careful management of resources and cross-training department resource the Clearing team was able to handle the testing volume, and was declared number 1 out of 52 banks for accuracy and completeness. Upon going live with the changes the bank was able to maintain its clearing commitments, a significant achievement when compared with a fellow international bank, who after one week of operation was one week behind on its processing and settlement.