Developing and Assessing Policy
- Anti-Money Laundering Compliance and Remediation
- Regulator Compliant Global Business Line Supervision Policy
Creating and Executing Business and IT Strategy
- Residential Loan Portfolio Strategy
- IT Application Portfolio and Platform review
Designing, Re-engineering, and Implementing
Financial Service Processes
- Early Warning Misconduct System
- Regulatory
Inspector Training Architecture
Gathering and Defining Requirements
- Major Federal Agency Revolving Fund Process Design and Integration
Architecting Emergency Management Plans
- Post 9/11 Emergency Management Planning
Providing QA and Operational Oversight
- Risk Based Inspection Program
- Tarp
Developing and Assessing Policy
Anti-Money Laundering Compliance and Remediation
Defined a policy for new client ID (Anti-Money Laundering review
of new clients) based upon UK regulator guidelines. Ensured that policy was "commercial"
as well as meeting regulator rules and guidelines. Remediated all existing
clients, requesting documentation as necessary. Extensive salesperson and client
education was required, as rules were not widely known or understood by non-UK jurisdiction clients.
Project was performed
under strict deadlines, interacting closely with regulators to discuss policy issues raised during the implementation. Completion of the project ensured that the Firm was in compliance with Regulator
guidelines, understood clients and risks, and obtained complete client documentation.
This project enabled an easier implementation of the post 9/11 US Patriot Act anti-money laundering
changes.
Regulator Compliant Global Business Line Supervision Policy
Defined division management supervision policy to comply with new Regulator
supervisory guidelines. Process involved defining points of risk,
defining controls and metrics, designing MIS reports, and defining and implementing a management sign off process.
Project kept Firm in compliance with Regulator guidelines, as well as outlined
points of risk for other projects, namely Basel II Operational Risk measurement and Sarbanes Oxley control requirements.
Creating and Executing Business and IT
Strategy
Residential Loan Portfolio Strategy
Developed a residential loan portfolio strategy including assessment of holding or selling into Secondary
markets. The analysis included the impacts of retaining or releasing selling
servicing, service rights impairment, competitive market pricing execution, best effort basis selling, mandatory
basis selling, hedging requirements, available hedging expertise, outsourced hedging options, and counter
party risk. Held loan analysis factors included sale of asset fee revenue
loss, balance sheet risk, loan liquidity, Secondary Market securitization options, and management awareness
of adverse underwriting charge selection. Additional considerations included origination unit P & L impacts, origination
unit alternative Secondary Market asset values, and origination unit fairness measurements.
IT Application Portfolio and Platform Review
Reviewed the application portfolio and platforms of a large regulator.
Elements of review included a survey of data and process gaps, legacy application costs, and current application portfolio
customer satisfaction. Technology platform review included cost and feature gaps. Improvement opportunities identified
ranged from application tweaks, consolidation of technology platforms, and an improved application management process.
The review designed a 5 and 10 year technology prioritization roadmap identifying applications and data base replacement
or redevelopment efforts constrained by available funding.
Designing, Re-engineering, &
Implementing Financial Processes
Early Warning Misconduct System
Developed a regulator’s early-warning misconduct system. Extensive interviews and information
gathering conducted with inspection and enforcement staff identified factors associated with high-risk firms
or sales persons. Extensive data analysis highlighted the most predictive risk variables. Appropriate statistical
techniques were identified for each variable based on analyzed behaviors. The statistical techniques identified normal
and abnormal variable ranges. The system produces alerts when a variable strays outside the normal range.
Regulatory Inspector Training Architecture
Designed a training architecture for regulatory inspectors of a large geographically
dispersed regulator. Surveyed key stakeholders and operational staff to frame architecture elements. Instructional
designers and subject matter experts co-developed paper-based and interactive training content supplementing in-person
training. Created and executed a regional level mentoring program. Developed a secure on-line certification application.
Gathering and Defining Requirements
Revolving Fund Process Design and Integration
Developed IT Strategy and gathered requirements for a $1 Billion
Federal Government Service and Supply fund offering over 60 cost center products. Gathered,
defined and prioritized over 1,000 process requirements and data models for the Budget Formulation, Budget
Execution, Rate Setting, Billing, Costing, Performance Management, Online Customer Reporting and Financial Reporting
processes. Performed fit-gap analysis, gap closure analysis,
and alternatives analysis against Oracle Projects capabilities. Integrated
new cost center product lines into the existing system leveraging a standard interface structure. Integrated existing system, processes, and interfaces into the world’s largest Oracle Financial System
and the US Treasury. Redesigned customer data structures to accommodate
new GL requirements. Post implementation review included gap closure recommendations
for the 30,000 transactions processed per month.
Architecting Emergency Management Plans
Post 9/11 Emergency
Management Planning
Thread lead for a large and geographically dispersed organization rectifying disaster response deficiencies.
Built broadcast notification infrastructure, a post impact staff check-in capability, and an alternative
work location network. Designed and implemented industry and regulator communication protocols for senior executives.
Designed and implemented mobility policy to reduce operational risk.
Implemented policy requiring staff to carry laptops off-site daily. Developed and implemented laptop mobility security
including data encryption.
Providing QA and Operational Oversight
Risk
Based Inspection Program
An NGO sponsored project for an emerging markets securities regulator required
a comprehensive set of Basel II compliant policies and procedures for a risk-based inspection program. The client
required increased inspection staff performance while reducing annual inspection cycle-time. The
regulator required extremely detailed procedures compensating for a non-existent local inspection training staff. A key deliverable
included a quantitative risk model identifying high-risk firms. The project analyzed in detail the financial market
structure of the client, contrasting sharply with the United States structure. In addition, the client country’s securities
laws and regulations were reviewed. A Basel II analysis was conducted contrasting to the UK and several other countries.
The project identified gaps and redundancies in the existing examination processes and procedures. The
project balanced the political dimensions of the client country and the NGO funding source.
The project was enthusiastically received by the client country and was subsequently leveraged into emerging market
projects in multiple countries.
Tarp
Assisted
US Treasury Office of Financial Stability in evaluation of the TARP program’s financial reporting, management
reporting, and internal controls.