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Industry · Banking

Controls and procedures that a supervisor can trace, from the rule to the person who did the work.

Operational procedures, control evidence and policy change move at different speeds across branches and back offices.

Example: Ashford Mutual Bank (fictional). Fictional organisation, fictional data, scripted answers.

What makes this sector hard

  • 01Branch and back-office procedures change at different speeds, so a branch can be following last quarter's version.
  • 02A change in the rules that apply has to be traced by hand to the procedures, contracts and controls it touches.
  • 03Bank statements and ledger entries disagree for days, and the differences are explained in email.
  • 04One failed control can stop several others, and the chain becomes clear only after an incident.

See it work on Ashford Mutual Bank’s own data

Simulation. Five short examples, one for each working area. The wording is scripted and no model is called; the figures are computed from what you decide, and a person’s approval covers exactly what you decided.

Choose what the branch assistant may answer from

What happened
Branches want an assistant that answers staff questions from the bank's procedures, and the head of operations must decide which sources it may read.
The question
Which sources may the branch assistant read, and which must stay out of its reach? Asked by: Head of branch operations.
  1. Choose what the branch assistant may answer fromChoose the sources the assistant may read. Restricted material cannot be chosen; a classification the analysis is unsure of must be confirmed by a person first.Open

    Choose the sources the assistant may read. Restricted material cannot be chosen; a classification the analysis is unsure of must be confirmed by a person first.

    Choose what the platform may read. Restricted material cannot be put in scope here, and a classification the analysis is unsure of must be verified by a person.

    Read it?SourceHoldsSensitivityWhat the analysis thinks it is
    Branch cash-handling procedures
    Procedures library
    74 documentsinternalApproved procedures clear
    Product factsheets
    Public website
    120 documentsopenCustomer-facing leaflets clear
    Fraud investigation case notes
    Case management system
    3,100 documentsrestrictedCase files clear
    Staff training modules
    Learning system
    210 documentsinternalTraining content check
    Customer correspondence archive
    Mail archive
    48,200 documentsrestrictedLetters and emails clear
    Internal policy bulletins
    Intranet
    390 documentsinternalPolicy notices check

    Sources in scope
    0 of 6
    documents in scope
    0
    Restricted, kept out
    2 sources
    To verify
    0

    0 of 6 sources are open to the assistant, 0 documents; 2 restricted source(s) stay out.

    The assistant answers from approved procedures, product information and training content, and never from case notes or customer correspondence [S1]. 0 included source(s) still need a person to confirm what they are before the scope is ready.

    Relies on: S1 · Procedure and records inventory (fictional)

    The head of branch operations with information security decides. Approving sets what the assistant may read for the pilot branches. It does not switch the assistant on, and it can be narrowed or revoked at any time.

    Not ready. Choose at least one source to read first.

Not done here. It does not read restricted material or customer records, and it does not answer from a source a person has not classified.

Where a person decides, and what is never done

Every example above ends with a named person approving it. Approving means exactly what is written here, and nothing more.

  • SOP IntelligenceDecides: The head of branch operations with information securityApproving lets: Approving sets what the assistant may read for the pilot branches. It does not switch the assistant on, and it can be narrowed or revoked at any time.Never: It does not read restricted material or customer records, and it does not answer from a source a person has not classified.
  • ComplianceDecides: The head of complianceApproving lets: Approving records the dependency picture in the control map. It does not change any control or report anything outside the bank.Never: It does not judge whether a control is adequate or report an incident anywhere: compliance officers decide both.
  • Financial IntelligenceDecides: The treasury accountantApproving lets: Approving raises the journals and queries for the items needing action. It does not post anything to the ledger or move money.Never: It does not post journals or move money: the accountant does, after reading each item.
  • Legal IntelligenceDecides: The head of legalApproving lets: Approving settles the wording to take to the product committee. It does not publish the terms or notify any customer.Never: It does not decide whether a change is fair to customers or lawful: legal and compliance do.
  • Executive IntelligenceDecides: The chief risk officerApproving lets: Approving records these assumptions and the result for the board paper. It does not change the lending plan or any limit.Never: It does not forecast losses or set a limit: the board sets the floor and the risk committee sets the limits.

Always a person in banking

  • A compliance officer decides whether a control is adequate; the platform shows the evidence, not the verdict.
  • The head of operations decides when a branch moves to a revised procedure.
  • Counsel decides what is said to a customer or to a regulator about a notice.

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