Leading UK Bank overcomes an infrastructure problem that put a key Remediation
Programme at risk – lessons learned
This paper describes:

A critical failure of Remediation infrastructure at a leading UK Bank

Subsequent recovery with a novel hybrid approach using software and spreadsheets,

Actionable lessons learned and a suggested infrastructure for other Banks
Call to action
We welcome the
opportunity to further
explore your needs
and discuss how our
Synapse technology
can meet them.
Please contact
Catherine Finch on:
0121 260 6000
catherinefinch
@synapseinformation.com
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Executive Summary
We describe a major remediation programme that experienced critical infrastructure
problems which put it at risk of breaching FCA commitments.
The need to use legacy Bank software systems was a given as was the proliferation of
spreadsheets to paper over cracks in the workflow requirements and support MI.
Together these two components created the rock and the hard place of unusably slow
system performance and incorrect data.
Unable to wait months to acquire more enterprise software the Bank collaborated
successfully with a specialist software company to make the in situ system both performant
and FCA compliant.
The solution to be described will work equally well for small, or in this case, large complex
remediation programmes.
The key solution elements built by the Bank:

The system had to embrace and integrate with the internally created spreadsheet
based processes, as well as other specialised third party software and multiple legacy
data systems. As a prerequisite, data quality and integrity had to be of the highest
standard and a defensible audit trail was essential to prove the final reporting was
valid.

Critical to success was the removal of dependence on IT and its replacement by
business user control of all adaptation to workflows, data validation rules, MI
production – in effect, all aspects of system operation.
The system had to meet the needs of a small remediation as well large complex
programmes, but in both cases, extreme agility was needed, i.e. set-up and running in
circa two weeks or not at all.

Background
The continuing intensive regulatory,
media and consumer focus on financial
services providers is resulting in a high
volume of customer rectification and
remediation
programmes
requiring
resolution, often via the means of a
redress payment.
Although we are
unlikely to see anything on the scale of
PPI again, this has set the tone for an
increasing volume of external and
internal reviews of current and past sales
processes and products.
Managed well, these programmes can
renew customer confidence in the
business and reinforce the message that
customer care is a core business value.
Poorly managed programmes however can
have significantly negative financial and
reputational implications.
Key to success is a pool of skilled resource to
manage each remediation programme, but
equally important is an infrastructure that is
intuitive, flexible and scalable so that the
business can maintain its regulatory,
compliance and financial commitments.
A critical failure of this infrastructure at a UK
Bank, and its subsequent rescue by the
Synapse solution, is the subject of this white
paper.
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Remediation challenges
The complexity of the remediation is often defined by how much time, effort, and financial
provisioning are needed to complete it. Simple rectifications such as issuing policy
documents that have been missed are often completed by BAU teams, sometimes in
parallel with their daily tasks.
More complex rectifications however require full time, skilled resource often supported by
complicated infrastructures governed by rigid policy guidelines.
The complexity of enterprise software remediation solutions is often a big part of the
challenge when remediation must be effected rapidly against a background of frequent,
regulator driven change.
These enterprise solutions are often excellent in support of large scale, stable environments
such as call centres where change in business requirements are infrequent. By nature,
Enterprise solutions have limited configurability while customised feature requests may take
months and incur significant costs.
In contrast, the regulator or the internal management may want changes immediately; the
pace of course is always driven by the need to make these as cost effective as possible.
For these and other reasons we see an abundance of spreadsheets to paper over the gaps
in the short term new functionality needed. Of course spreadsheets bring their own well
known problems of poor data quality, integrity, limited audit etc.
These hybrid Enterprise software and ad hoc spreadsheet solutions exhibit a number of
challenges which serve to increase reputational and financial risk:

How do we create a single view of all
impacted customers? How do we do
this when they are spread across
multiple business areas and locations?

How do we react quickly enough to
adapt to changing demands to satisfy
internal and external stakeholder
expectations?

How do we embed effective controls
around the data and ensure its
integrity, validity and accuracy to
support critical reporting timescales?

How do we minimise the negative
impact that internal IT policies bring
vis-à-vis getting systems changed
quickly, economically and effectively?
From this we can see that finding and implementing the right solution is often the most
challenging aspect of successfully delivering a remediation programme. We describe next
how Synapse has developed an innovative and highly flexible solution that has delivered
significant benefits for a leading UK Bank.
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What is the right software infrastructure solution?
As described, for these types of programmes, companies naturally first turn to enterprise
solutions that are either outsourced or developed in-house. Generally these solutions will
initially meet the immediate needs of the programme but as requirements evolve,
problems accumulate due to their inherent lack of flexibility – they were not designed to be
user adaptable.
To address these shortcomings, the most common practice is to turn to the familiar
spreadsheet: Microsoft Excel is of course a ubiquitous, in place corporate standard.
Frequently, Excel is used to support some of the most critical aspects of the remediation
process such as capacity modelling, progress monitoring, progress tracking and regulatory
and financial reporting.
Excel is a system business users are familiar with and trust. They can rapidly develop their
own solutions with no reliance on internal IT - this means they can meet the speed of
change required.
This flexibility is the reason the business turns to spreadsheets, but the inherent data quality
problems are so widely publicised we will not recite them here; rather we shall give
examples from the Synapse remediation customer, a leading UK Bank.
Industrialising the Bank’s spreadsheets
The Bank’s spreadsheet based solution encountered severe problems:

Users worked with out of date data without fully realising it – current records
would be overwritten with stale data.

Lack of business rules (data validation
and controls) built in to the workflow
meant that data error and loss occurred
from the outset thereby incurring
regulator risk by missing MI deadlines

Severe performance and stability
issues resulted in significant downtime
which impacted productivity and
confidence in the infrastructure.
Faced with
the
severe problems
described, the Bank asked Synapse for a
solution.
Background to the specific problem




A complex remediation programme impacting over 800,000 UK customers and 1.3
million products.
A critical challenge was issued by the regulator to improve remediation processing
The programme had been using multiple single spreadsheets to work cases and
produce MI.
Initially, 40-60 case handlers using these spreadsheets could not get real time
concurrent access to a single view of the truth.
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

As the user population grew, the performance reached critical levels and
considerable time was being taken up manually producing the MI, meaning it carried
a high level of data accuracy risk.
There was an unmet need to integrate fluently with the Banks enterprise software case
handling solution meaning that multiple extracts and loading scripts had to be
maintained.
Within 2-3 weeks Synapse was able to prove a resolution to all of the problems described
was feasible. Following this proof point the Bank has invested its trust and confidence in
Synapse to evolve a joint solution to meet their customer needs and regulatory
commitments.
Solution in detail
Synapse was asked to build an end-to-end solution to enable the mobilisation of a number
of cohorts. Working in collaboration with the project team, the first delivery was met within
a further three weeks.
Significant evolution has taken place since implementation with very positive outcomes:



The programme continues to meet its 
reporting and progress commitments in
line with policy guidelines
Today, up to 465 concurrent case
handlers use Synapse with no outages or

performance issues
There has been a reduction in the time
needed (from 14 days to between 3 and
5 days) to compile monthly MI reporting
and timely and accurate regulatory

reports.
The Business control and implement their
own business rules and validations to
meet changing demands; there is no
reliance on the Bank’s IT or an external
enterprise software company
Compliant control of the source data is
achieved
through
bulk
upload
functionality; audit trail, back-up and
restore functionality ensures that this is not
compromised
Administration of the Synapse system
(user access control, report scheduling
and ad hoc activities) is all performed by
the business users that are appointed by
role.
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The project will run for a further two years with Synapse contracted to provide a central role
in the control and management of the data and the outcome reporting.
A key reason that the Bank chose Synapse is that the solution is not mere technology, i.e.
the Synapse team combine advanced technical skills with a fluent understanding of the
business issues that need resolution.
These two skills mean that making significant functional changes can be achieved at a
very rapid pace. The Synapse solution has been highly configured to fully support the Banks
unique process flows.
Summary
Industry commentary suggests that regulatory focus on current and past sales will continue
to be a rising trend for the medium to long term future - as evidenced by the £2BN fines
levied by the FCA in 2014 alone.
This increased scrutiny from regulators, media and consumers will result in more rectification
and remediation programmes being established. As the pace of regulatory demands
heats up, an infrastructure that is highly configurable, owned by the business and that can
deliver the speed of change internal and external stakeholders require becomes a must.
Synapse has built their remediation solution – in collaboration with the Bank – to achieve
exactly these goals. Focusing on extreme flexibility, Synapse offers the following capabilities
as a standard set of features:
Capacity modelling, resource allocation, case workflow, quality checking and accurate MI
Integration with existing enterprise solutions in place.
Synapse will help ensure a controlled, stable and secure environment meeting strategic
and regulatory objectives, whilst providing a single view of all customers.
Because all transactions passing through the Synapse server are fully audited, the
capability for root cause analysis to deliver performance improvements and eliminate
financial and reputational risks is built in.
We provide proven expert consultancy, project management and business analysis expertise. We work
closely with your teams to ensure all requirements are met, all improvement opportunities are identified and a
great working relationship is forged.
If you would like to know more about Synapse and how we
can improve your spreadsheet experience, get in touch:
0121 260 6000
Synapse, Faraday Wharf, Holt St, Birmingham, B74BB
info@synapseinformation.com
About Synapse
Synapse was founded in 2012 by a British team of highly experienced Silicon Valley veterans with
extensive experience in sophisticated data management solutions. Our solution has been built in
collaboration with a Government R&D investment in SMART technologies. Located at the Innovation
Birmingham Campus, Synapse is at the heart of the technological innovation hub of the Midlands.
Synapse customers include a global Swedish retailer and a leading UK Bank.
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