Posts Tagged ‘Mortgage Bankers Association’

An Allegory for an Uncommon Time

Tuesday, June 22nd, 2010

By Mark P. Dangelo

www.innovative-relevance.com

(as also published at the National  Mortgage Bankers Association)

In a dark cave, a fire glows in the corner casting its shadows with eerie reflections on the objects within.  In the flickers of light, we can see outlines of gray and black hues sketching out eight individuals – all chained together, all facing forward. 

For decades, each of these figures –consumer, banker, GSE, financier, investor, regulator, politician, and technologist – faced the wall in a sitting position gawking at the dancing wall images encapsulating a unique reality for their daily existence.  Each saw their reality in isolation even though the images of their existence were created from the same source.

The cave, and its changing shadows, was the only existence this group of eight had ever known for business, markets, and individual reward.  The inhabitants had never left the cave, yet each was firm in their own but different, realities.  Their livelihood and prosperity was the cave.  It was comfortable, convenient, and it defined their existence. 

A Seismic Disruption

Just over two years ago, a magnitude 8.2 financial seismic disturbance unshackled the cave dwellers from their bonds, and the light that reassured them of their existence sparked and began to rapidly dim.  In short, the seismic aftermath freed each of the linked from their one-way value chain of subsistence.  As they rubbed their dust cover faces, they witnessed a new illumination coming from the entrance of the cave. 

Disoriented and driven by failing debris, the historically interconnected dwellers were separately forced into the open and the strange confines of a new world.  Grasping, groping, angry, and seeking safety, the eight moved to the glow of new surroundings, as a method to escape individual and financial demise now being delivered by the cave that once protected and sustained them.

For the group of eight (G8), their survival outside of the cave was savage.  Month after month, their long-held axioms were shattered – home ownership, mark-to-market, hedging strategies, derivatives, regulatory certainty, housing markets, ethics, investor confidence, sovereign wealth and currencies, consumer behavior, regulatory oversight, risk analytics and strategies, swaps, structured financing, fiscal responsibilities, and even government-backed enterprises, which have the potential to saddle taxpayers with $1 trillion USD in losses against the national debt (multiples greater than AIG). 

Moreover, the G8 were challenged by those who had already lived outside of the cave, as they were acclimated to behaving and interacting across new world commerce.  These “global dwellers” had different mores, protocols (i.e., regulations), and business demands quite distinct from the G8.  The original G8 longed for the prior security of their cave. 

For the next 827 days, aftershocks and misplaced initiatives dominated their interactions with these global dwellers, and those that indirectly had come to depend upon them.  The G8’s prosperity (i.e., cave light), as defined by their historical cave surroundings, was being extinguished.  A new illumination was coming from a different source delivering ever changing images and realities – a radiance that was high in the sky rising from the East.  The G8 were grasping for efficacy in a new environment as the rules and workflows of operation were regularly failing their original creators.

For the G8, as they exited from cave their global wealth steadily declined by over $20 trillion, as triple-A asset backed securities and complex, opaque OTC derivatives fell in value or vanished all together.  As the markets fell, business interactions among the G8 declined resulting in 1 in 10 domestic adults being unemployed.  Moreover, unsustainable household debt or leverage approached 200% of income as government debt reached WWII ratios against GDP.

The shockwave of unemployment and survival conditions outside of the cave inverted the ratio of new mortgages when compared against delinquencies and foreclosures. Calendar 2010 promises nearly 3 million repossessions and short sales against an average of 650,000 originations.  Private securitization fell from over 60% in 2006 to < 2% in 2009.  Moreover, 2010 brings new survival risks for the G8 cave inhabitants, as global dwellers and their investors demand new restrictions as volatile sentiment creates lingering doubts – and the potential retracing (e.g., double dipping) of the on-going survival pain. 

Life on the Outside — The Unthinkable becomes Commonplace

New behaviors and strange occurrences for the G8 grew.  Consumer strategic defaults became commonplace as “underwater” became a key justification for default.  Bankers reluctantly became “utility” providers, as they never thought their actions would become public record – let alone achieve such a level of public vilification.  Making matters worse, HAMP, which was promoted with the hope for all the G8, is now facing the potential of a 75% re-default within 12 months for those already “helped.”

Even those “Sheppard’s” of the old cave – the regulators, their agencies, and politicians – now added more uncertainty and strange behavior. This diverse trio reacted to the demands of the global dwellers, and the chaos they were unprepared to experience.

Individually and using public forums, once comfortable regulators found their relationships and new world frightening.  They chose to hide behind the nearest tree to avoid retribution or inspection.  Politicians blamed everyone around them as a global distain grew into domestic consequences – their role and reelection appeared no longer ordained – as some were having tea while others were distributing wealth and retribution. 

Investors and brokers now realized, what meteorically goes up can crash to the ground destroying their secure cave and everyone in it.  It was no longer a game or an illusion on the wall of the cave.  It was real, and the consequences dehumanizing.  Actions and results went well beyond the “education” of the markets and informed investors, moral hazards, or even “the greater good.” 

And yes, the technologist who was seeking to streamline processes for operational efficiency (i.e., the interconnected images on the cave wall), find these new global dwellers offensive, belligerent, and failing to accept the storied accomplishments once taken as gospel within the cave.  Their prior status seems to have little meaning to the global dwellers, who have established themselves and their markets without the dogmatic expertise of the G8 “cave interactions.” 

Finally, after a year of debate and blame, in an effort to create a new “virtual” cave, the G8 proposed new guidance for their surroundings.  This guidance was designed to ensure their relevancy and standing in the “new world order.”  They would “set things right.” 

Creating a sweeping series of changes, captured in hundreds of thousands of words and legal language, the G8 sought to create an innovative reality – a “better” reality.  It was a new set of standards for all to follow and admire – to ensure that the collapse of the new, virtual cave can never happen, like the “real” cave did. 

In an effort to adapt to its new global surroundings, the G8 members lobbied, shouted, projected, and cajoled not only each other, but those new relationships they needed for survival and prosperity.  The new world order was now close at hand as the G8 demanded adherence and respect.  But, were these “sound laws” enough?  Too Much?  Or was it all just another illusion – more than business justification and markets demanded – to wield influence and “stake out territories?” 

Rebuilding Against the After Shocks

So dawns a new quarter as the G8 lobby for and lament against financial reform and revolution.  Nearly three years after their cave collapsed, those original eight who were holistically linked have fractured and polarized.  As the pillars burn, for many innocents caught in a financial disruption not of their making, the Four Horsemen have arrived in rumbling droves. 

However, from the ashes of illusion, hope arises – and we believe prosperity will be forthcoming, driven by new guidance and innovation.  But when?  Who will be the beneficiaries?

Contrary to the hope of G8 members, rebuilding does not mean the same or even retro.  Very little will be the same, and the time machine is out-of-commission.  The old cave light taken for granted as the “Sun” by the G8 is now larger providing illumination for all the global dwellers – not just those within the destroyed bunker.  This “New Sun” (rising in the East) is not easily controlled, and it must be harnessed differently if a new ecosystem of co-dependent business models is to be sustained. 

However, for those adjusting to the global dwellers and their “strange” relationships, there is a material risk.  If they adopt and adapt to new behaviors and methods of business, will they be shunned (or worse) should they return to their original G8 members?  Will they recognize their old friends and foes?  Will they be cast aside by those who still favor those dogmatic methods, which once led to prosperity – but sowed the seeds of the largest financial seismic disruption in 80 years (but the largest in net losses)?

For the G8, questions remain in the effort for transparency and viability.  A cursory few include:

·         Consumer:  Will their new “cave” be dependent upon old ideals?  Will they behave so differently that only “educated” owners will be allowed to participate in the new society?

·         Banker:  Will their longing for the historical, be the seeds of their slow demise?  Have their sunk costs of cave participation become so culturally ingrained that they only are perceived to change when forced?

·         GSE:  What will their role be after the “period of convenience” ends?  Are they the next “public-private” villain as the global dwellers seek a new leader(s)?

·         Financier:  Where’s the deal, what’s the spread, and how can it be hedged?  Is this new world really any different than the old one?

·         Investor:  What will be recoverable and who was to blame for their loss of stature and capital?  We were “mislead,” right?

·         Regulator:  What are the implications and impacts of action or inaction?  Is it a global world or “each cave / clan for themselves?”

·         Politician:  Am I interfering in the life and property of “my subjects” with “proper justification?”  Is it safer to be “feared than loved?”

·         Technologist:  Do we have the new skills, processes, data, and architectures needed for conformance and compliance?  Will the existing become immaterial?

Rebuilding, as Machiavelli wrote in 1513, is a torturous compromise, “Men have imagined republics and principalities that never really existed at all.  Yet the way men live is so far removed from the way they ought to live that anyone who abandons what is for what should be pursues his downfall rather than his preservation; for a man who strives after goodness in all his acts is sure to come to ruin, since there are so many men who are not good.“

* * * * * * * * *

So even after nearly 2500 years of allegorical symbolism, it still appears that our parable has not reached its conclusion – not yet.  For lurking within the woods and waters surrounding the recently combined global dwellers, including the G8, are bears, bulls, bugs, horses, reptiles, lions, sharks, snakes, and may be an iceberg.  The environment has changed, the interactions uncertain, and predators are many.  The only axiom still valid is that a new equilibrium has not been achieved. 

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In Times of Renewal, Everything has Value – Not Everyone Sees It

Tuesday, May 18th, 2010

By Mark P. Dangelo

www.Innovative-Relevance.com

As everyone is busy digesting and commenting on financial regulatory reform, a new crisis is quietly unfolding.  Alongside markets, consumers, and investors demanding “different” behaviors, the operational “glue” that binds organizational and system interactions is rapidly losing its adhesion.  The rules of success and organizational profitability are permanently changing, and our trusted and certified systems built with precious CAPEX are losing their efficacy.

“How can this be?” is the typical response, “We measure everything!”  Although, if we examine historical organizational results or performance and project the KPI’s (key performance indicators) forward over the next 18 months, will we be so steadfast in our assertions?  Are the business case justifications and future relevancy for technology driven business solutions still relevant?  Do we have the blueprints or even the architectural frameworks, which secure operational capability to construct new products, deliver bespoke services, or even meet future compliance mandates?

Like many organizations examining their future, the relevancy of existing business processes touching people and systems, across all pillars of finance and mortgage innovation, is fast becoming a competitive liability.  Hemmed in by legacy systems, inadequate governance practices, n-1 generation skill sets, market and organizational transformation, inherited business processes have become arcane and expensive to maintain. 

It appears that an idea of “rigorous self examination[i]” within finance and mortgage groups (FMG) should not be limited to just Goldman Sachs.

Not Everyone Sees It

So, what do all the challenges mean for finance and mortgage organizational renewal at a time when budgets are thin and survivability a top corporate goal?  Is there a proven, universal approach that can be positively utilized for short-term gains with “long-tail” benefits?  How will CAR’s (i.e., challenges, actions, and results) be orchestrated, and more importantly, when will they hit the bottom line? 

However, you may be surprised to learn that hidden within our own organizations’ often resides the answer, the framework, and the (iterative and incremental) approach – business process management or BPM.  BPM is frequently practiced, but not always seen, let alone understood.  Additionally, some believe that BPM is merely a series of disciplines and technologies cobbled together in the early 1990’s, and are not up to the challenges of today’s finance and mortgage innovation demands.  They ask, “What is so special about BPM two decades after it was introduced?”

Historically, BPM has been widely accepted and practiced within IT divisions, while subsequently being provisioned by vendors using architectural approaches such as SOA and SaaS.  Yet, the BPM “call to action” represents a holistic and comprehensive set of interrelated disciplines, “promoting business effectiveness and efficiency while striving for innovation, flexibility, and integration with technology.[ii]” 

Now, with two decades of validation and improvements behind it, BPM is being utilized for more than modeling and simulation.  Today, BPM is being deployed for cost savings (e.g., with results from 10% to 35% ROI), cost avoidance, business adaptability (i.e., agility), and profitable “To-Be” roadmaps, which knit together technologies, operations, and data regardless of geography or platform.  It has found unreserved respect among select, internal champions – but moving forward, BPM will become a corporate agenda item recognized for its versatility and repeatability in driving organizational excellence and continuous innovation.

BPM Case Study Benefits and Outcomes– Large U.S. Retail Bank[iii]

·         Gained competitive advantage against leading larger retail banks:

o   Standardization of credit packages

o   On line application for customers allowed to process factor 4X more credit applications

·         Increased customer base by 25% in one year

·         Lowered operational risk via automated credit check processes and fully automated risk compliance management (i.e., real time dashboards)

·         Reduced staff by 20%

·         Optimized Bank’s working capital via better P&L management

·         Overall productivity increase reached 35%

According to Pedro Fong, BPM Senior Manager at SunGard Consulting (SGC), “The potential for tangible returns using BPM are there.  Nevertheless, the key factors for sustained success reside with the proper alignment of BPM approaches to the goals of the organization.  Experientially assessing how much an enterprise is prepared to invest (i.e., time, people, capital, implications) in making those goals a reality, influences the plan of attack, number of iterations, technology, and the establishment realistic performance benchmarks.” 

For many FMG’s dealing with three years of chaos, losses, and buybacks, BPM has become an organizational stealth competency – or weakness – that cannot be ignored.  Implicit in bringing BPM into the FMG executive agenda is the full recognition of dependent programs, cross-department productivity, and required organizational change mandates. 

Everything considered, by ignoring BPM as the glue which binds organizational transformation and growth, management will likely document an inaccurate picture of progress, benefits, costs, and opportunities.  The result is misplaced accountability and performance driving decisions and investments.  We have to ask the question, “Is this why for the last 15 years over 70% of all organizational initiatives consistently fail to meet their approved charters, criteria, and KPI’s?”  

BPM: Built for Relevancy – Architected for Results

As everyone is eager to “Retweet,” there are some embryonic signs that the domestic and global economy is finally improving.  In fact, John Paulson, the hedge fund manager who made billions predicting the housing market collapse, is now foretelling an impending “V” recovery in 2010 across the markets hardest hit – particularly California. 

So if the markets are recovering, why worry about rebuilding processes or streamlining them for efficiency?  After all, if you are reading this you survived the worst recession in 80 years.  No need to change now as the crisis is past, right?  

Encapsulated within the aforementioned inquires resides one of the greatest mischaracterizations of BPM – that it is only useful when times are tough or “something is broken.”  The benefits and value propositions inherent within a robust BPM framework provides the roadmaps starting at the “macro” and moving into the “micro” – not to mention the ability to traverse and audit processes in reverse. 

As shown in Figure 1, BPM practiced in the hands of experienced personnel provides the iterative and collaborative design that envelopes better publicized improvement methods (e.g., six sigma).  Also, BPM can proactively address the necessary adapters required for existing and emerging technologies along with their provisioning practices (e.g., SOA, SaaS, IaaS, BI, et al). 

Figure 1 — www.innovative-relevance.com/MBA051810Fig1.html

Mr. Fong asserts, “For finance and mortgage organizations, BPM has always been about the proper determination of operational impacts, which can be estimated in such areas as throughput, performance, risk, quality, and availability of data.  ” 

BPM is architectonically organized to achieve results regardless of the operating conditions being experienced.  Upon detailed inspection of Figure 1, we note that the utilization of the generic BROC3 framework (or its equivalent) yields consistently measurable actions and results underpinned by technology and implementation techniques.  For FMG’s pursuing renewal, internalized BPM approaches (like BROC3) can mean the difference between commodity positioning – or market leadership.  

When asked about the proper deployment of knowledge solution sets, Mr. Fong says, “By leveraging technological innovation (e.g., cloud computing, SaaS, SOA) to implement and measure processes (e.g., via dashboards, analytics, and BI tools), organizations are able to create financial and customer insight unknowable just three years ago.  For BPM, technology represents the efficient use of scarce resources, while improving an organization’s ability to create, model, and share new business processes across the entire organization.”

Everything has Value

As we have intrinsically acknowledged, current survivability does not guarantee future organizational sustainability.  Moreover, advanced technology adoption seldom guarantees competitive differentiation – let alone lasting profitability or repeat customer loyalty. 

As noted recently in the Financial Times[iv], “… since 1977 about 700,000 new businesses have been started in the U.S. every year.  The number barely changes from year to year.”  With high domestic unemployment (national average > 9.5%) and record business failures since 2007, the extraction of organizational and operational value cannot be left to chance – or misplaced on a corporate initiative not grounded in realistic quantification. 

So what should we do?  Where is the value hidden and more importantly, how can we get approval to release it from the grips of organizational dogma?  Frankly, do we even have the time needed to reinvent our operations before the next wave of FMG crisis descends on already precariously weak balance sheets?

The answer to these questions, challenges, and opportunities commences with the identification of a business case for BPM.  As granularly presented in Figure 2, Defining the BPM Business Case for Finance and Mortgage Groups, there are many beneficial areas that occur along a continuum of organizational importance.  Moreover, Figure 2 also clearly shows that to ensure your FMG business case survives scrutiny and skepticism it must be tempered against operational requirements, rigor, and yes, reality. 

Figure 2 — www.innovative-relevance.com/MBA051810Fig2.html

 

“The lasting value of BPM is frequently marginalized by the lack of robust business measurement criteria,” say Mr. Fong.  “To ensure organizational sponsorship and support, the business case must be completed as part of developing the project charters and plans.”

However, Mr. Fong also cautions organizations that “BPM is an excellent discipline, but it is no ‘silver bullet’.  All FMG BPM efforts need to be viewed as components of a company’s overall strategic roadmap to meet the needs of the organization and to support the business goals.  These BPM efforts need to be become part of how the organization thinks and reacts so that they are internalized and allowed to evolve.  As with similar methodologies or PI (process improvement) efforts BPM should be viewed as a tool that an organization can use to achieve improvement milestones and lasting operating success.”

As we can now summarize, BPM should not be approached casually or as a “hammer seeking a nail.”  To make BPM more than a slogan or theory, it must align with the business model and a concrete case for its existence must be established.  BPM is much more than a set of IT tools or vendor solution sets.  Whereas, there are short-term benefits that can be achieved without a detailed business justification, if left unattended BPM will languish or be misapplied to situations that are better suited with complimentary approaches.

As demonstrated, the returns and costs of BPM spans many issues within FMG’s.  Provided as examples in Figure 2, you can see some of the items that may resonate with business leaders who are signing the “checks” for BPM enabled programs.  By qualitatively and quantitatively determining “what has value,” your BPM effort is taking an important first step on a journey to reach a proper fit not just for a given business model, but the against the culture, technologies, and operating characteristics of the enterprise. 

* * * * * * * *

It was Lao Tzu, the founder of Taoism, who said, “The journey of a thousand miles begins with a single step.”  BPM for FMG’s is both a place (i.e., discrete conclusion or end result) – and a journey of continuous process improvement delivering concrete organizational outcomes.

As we have examined in Figures 1 and 2, the adoption and adaptation of BPM creates an operating environment that is healthy and proactively aligned to changing business models, economic challenges, and consumer behaviors.  Careful and in-depth study of Figures 1 and 2 will yield additional insights and questions that I cannot address in a single article.  Perhaps I’ll save those for another column, as we didn’t even mention the outsourced and shared services implications for BPM transformation, governance, or delivery.

In conclusion, BPM is suited for “one-off” situations as well as enterprise transformations.  It is the hidden glue that binds our people, technologies, and data.  When the glue fails, our operations become like “Humpty Dumpty,” — no amount of money, people, or technology can singularly put it right.  Without managed business processes, without the glue and its adhesion, we will eventually fail.

 


[i] Lloyd Blankfein, Goldman’s chief executive, May 7, 2010, as published in Financial Times.

[ii] Wikipedia, definition for business process management.

[iii] Data furnished by SunGard Consulting.

[iv] “US Unemployment,” Financial Times, May 10, 2010.

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Data Integrity – The “Movable” Pillar of Discovery and Substantiation

Wednesday, April 21st, 2010

By Mark P. Dangelo

www.Innovative-Relevance.com

Integrity.  A character defining word that ranks with ethics, morals, and principles.  Its denotation affirms exceptional personal conduct, while its business implications suggest repeat customers, market status, and brand durability. 

More to the point, who can argue with the need for integrity, authentication, and chain of custody when it comes to financial and personal data that must be examined under scrutiny, forensics (e.g., fraud, transactional), or penalty of law? 

Whereas integrity principles are accepted as beneficial, it is in the achievement of these goals where money is lost and legal cases won – or lost.  There are cascading and hidden risks within, which are only surfaced when misfortune (e.g., delinquencies, foreclosures, class-actions, securitization failures) is internally recognized. 

Yet, for many individuals and organizations, the realization of integrity for data is something more mysterious.  It is commonly pushed deep into the enterprise — to the technologists in the back office.  Data integrity has little relevancy or correlation with today’s corporate strategies, operations, quality conformance, and profits.  Right? 

Fallacy and Reality

It seems every five to seven years, industry specialists and business leaders declare victory over the “hydra” of data integrity – classically defined as having three components of entity, referential, and domain.  With “victory” achieved, the organization and its focus shifts to the next problem or market challenge vexing its bottom line.  The data integrity requirements and regulatory mandates (e.g., business rules, data life-cycle, fail-safe controls) fade into the realm of IT myth and folklore.

However, with the steady advancement of technologies and practices (e.g., guaranteeing of data integrity in public cloud computing environments), the acceptance of demise for data integrity requirements creates false security – and lurking liabilities.  Like the hydra of mythology, the requirements compound and grow back (like the heads of the legendary beast gaining ferocity), becoming a menace to operational sustainability and business viability. 

With litigation and due diligence surrounding the data elementals of handling, storage, authenticity, durability, touchpoints, and isolation on the rise, it appears that hydra of integrity has found new life.  Some common data integrity misconceptions are frequently voiced as:

·         “Since our organization has structured application systems for our FMG (finance and mortgage group) operations, isn’t it a given that we  have the data integrity we are required to have for regulatory compliance?”

·         “We have standards for data entry fields, so why should we be concerned about the elements within the data repositories, marts, applications, and storage farms?  Isn’t data integrity really just about standards and field capture?”

·         “Data integrity is only about old application systems and approaches (e.g., flat files, VSAM, spreadsheets, point-based systems).  We have a commercial database and have spent years creating robust functionality in our origination and servicing systems.  Data integrity was taken care of years ago in our organization.  Sounds like much to do about nothing– like the IT department looking for a budget increase.”

Some of you reading this are probably just about ready to find another article that is more “edgy” or “important” to your organization.  Some would argue, this topic is old and stale and has very little to do with 3-years of housing’s turmoil and the current challenges facing FMG survival?  Let’s take a quick look at just a few of the realities documented by various organizations.

·         Annual price tag for bad loan data in the U.S. financial markets was as high as 7.3% of revenue – QAS Research, a unit of Experian,

·         FDIC reported that over 83% of the mortgages they audited contained violations,

·         Over 50% of the data corruption and integrity issues reside outside of technology – IBM, “Transforming Enterprise Information Integrity,” and

·         With over 90% of all records stored electronically (or scanned into electronic formats), the ability to maintain integrity over the life of the financial product (and for compliance) is material.

Moreover, with existing and pending legislation, additional concerns arise for the integrity of historical data stores and for future databases.  A very small snippet of these include (depending upon your business and model):

·         Consumer protection agency and its proposed charter,

·         Rule 803(6), U.S. Federal Rules of Evidence (see Info Law Group, “Privacy, Security, and Intellectual Property Law,” January 29, 2010),

·         “Skin-in-the-game” implications of Congressional financial bills (i.e., consequences of “cradle to grave” data life-cycle demands for definition, discovery, and defense), and

·         Existing and proposed state sponsored “breech” legislation – and consequences.

To believe that the guarantee of data integrity has been “met” across financial markets that are redefining rules of operation and conduct is fraught with peril.

A Principle-Driven Data Integrity Approach

For experienced enterprise architects, the utilization of principle-driven approaches is familiar – and represents stability and consistency for ever-increasing technological options.  Made famous in the “IT Paradigm Shift” by Don Tapscott and Art Caston, the use of the PRI (i.e., principle, rationale, and implication) architectural framework has gained global acceptance especially with the deployment of specialized technologies, layered outsourcing arrangements, and application compartmentalization. 

With estimates currently ranging from 4% to 9% of an IT’s budget directly or indirectly being consumed by information discovery, due diligence, and defense, the life-cycle challenge of data integrity cannot be left to chance. 

Table 1 provides an illustrative example for IT and business leaders of the granular and interdependent PRI’s, which are needed for the next decade.  So before you purchase the next origination system, sign up with a servicer, or restart private securitization efforts, ask yourself, “How are we addressing these areas, at what cost, and with what exposure?”

Table 1 – Illustrative PRI for Data Integrity / Data Architectures

Principle

Rationale

Implication

To guarantee adherence to organizational values, data custody and authentication must be able to be verified and certified by an objective and qualified third-party.

·          With the rapid adoption of cloud computing solution sets, data routing and its transmission cannot be assumed to be tamper proof.

·          Sequencing of data segments, since they may come from multiple sources and technology platforms, must involve the full acceptance of the data record or demand a complete rollback of all elements.

·          More than ensuring data and time stamps.

·          Demands more than standard hashing algorithms.

·          All data transmitted across public networks and from layered applications will be subject to predetermined certification tests.

·          Best practices will be adopted / modified to ensure data integrity of the highest quality.

·          On-going / continuous monitoring.

The validity of data and its consistency of capture, storage, and usage must conform to all published enterprise standards and applicable in-country regulations (e.g., privacy, confidentiality, et al).

·          Enterprise data demands must recognize disparate requirements, laws, and compliance demands when crossing local, state, federal, and international borders.

·          Within pending regulations, new implications of handling, storage, and usage will be demanded, with the “old” practices requiring a different set of data integrity “release” parameters.

·          If data is shipped in a cloud, its route should not violate laws on its path to corporate systems (a current challenge for network data routing in a cloud).

·          Compartmentalization of data management elements, schemas, and logical representations (along with all the rules and validation edits), should be maintained and able to be reconstructed for the life of the data.

Unless explicitly exempted by data owner, all data, rules, and manipulation must be implemented utilizing “data isolation modules” (DIM’s).

·          Identify and ensure fail-safe controls.

·          Ability to reconstruct “versioning” of data evolution at a discrete or elemental level.

·          Minimize reoccurring expenses associated with development and application segmentation.

·          DIM’s will have been validated and certified by custodian of record.

·          Taxonomies of data must be developed and maintained.

·          Any exception must be documented and sanctioned by corporate officer.

·          Use of (n)XML standards for data interchange and portability.

·          Common data models.

Data must be classified by both durability and risk to uphold usage, archival, and retirement.

·          With changes in technology solutions (i.e., technology is the least stable part of an architectural solution), portability and availability of data must be guaranteed.

·          A comprehensive data life-cycle approach for ensuring data integrity goes beyond application and database systems.

·          Part of a robust master data management (MDM) approach.

·          Years after the original transaction, due diligence demands will require a comprehensive review of all touchpoints including the outside review of litigants.

·          Workflows must reflect data requirements.

·          Rules engines do not singularly satisfy data integrity demands.

Data, and the transactional streams used during their life-cycle, must adhere to / exceed all auditing, logging, and compliance requirements.

·          With litigation on the rise, the “states” of data, its manipulation, and its usage must be captured across all its forms / transition states.

·          To support processes and regulatory demands, the data underlying the organizational certifications must be managed according to generally accepted practices that have been proven trustworthy in a court of law (i.e., they should be accepted by corporate legal advisors and auditors).

·          Use of robust WORM solutions according to performance, regulatory, and cost constraints.

·          All DIM’s and associated API’s must be certified.

·          Off-the-shelf certified solutions that incorporate industry standards, will be given preference during system “ever-greening” (to reduce capital costs, custom tailoring, while ensuring repeatability across multiple locations).

·          Monitoring and benchmarking of adherence will be done every (xxx).

Data sourcing, sequencing, and trustworthiness (SST), must be identified and maintained over the life-cycle of the data in adherence to corporate data standards and practices.

·          A clear system of record must be defined and maintained to guarantee efficacy and integrity.

·          With the data sourcing chain now firmly linked across origination, servicing, and securitization, access to the original data source (and the guarantee of its integrity) will be a top 5 corporate responsibility (and potential expense) during the next decade.

·          The use of “ACID” properties should be part of the certification process.

·          Use of existing and evolving data standards will be favored over internal, one-off solutions (to reduce costs, risks, and ETL requirements).

·          Developing and delivering data intelligence (DI) as part of standard operating procedures.

·          Strong and enforceable (with consequences) data polices.

NOTE: Illustrative and abbreviated for presentation purposes

 

After reviewing this lengthy table, some will ask, “Where’s the technology?  Where are the explicit standards?”  How can you have a data integrity architecture without solutions?” 

If we could add additional columns to the right, we would then add in the technology and discrete solution sets needed to deliver the principle-driven architecture that has been rationalized with its interdependencies.  So far, we’ve aligned organizational need, identified processes, and touched on the need for personnel and skills.

Perhaps the questions that make more sense for business personnel using this approach include, “What technologies are required to satisfy the business needs and operational requirements (inherent in the business and operational needs of the first three columns)?  What solutions best fit our ‘As-Is,’ ‘To-Be,’ and gap implementation programs of work for minimal capital costs and maximum return ensuring data integrity rigor / discipline?”

So yes, data technology and standards are very important – but only after the operating parameters have been articulated and approved.  They will vary for nearly every FMG driven by their management team, markets, and current challenges.  The interesting aspect of this proven approach is that once defined and maintained, it works in concert with numerous development or provisioning methods, applications needed, or outsourcer selected. 

In summary, the data integrity principles outlast the technologies, promote non-linear decision making, and “hold up” under the scrutiny of review.  For business leaders signing the checks of new solutions, it gives tremendous business case justification to “why IT does matter.”  And, when it comes to legal and regulatory challenges, preparation and anticipation are always cheaper than intrusive discovery and evidence gathering.

Challenges within Cloud Computing and Virtual Data Provisioning

Last, but not least, are the data integrity challenges materializing within cloud solution sets.  Since cloud computing and associated data storage options are one of the fastest growing offerings (e.g., Amazon, IBM, Dell) we cannot neglect the evolving issues of data integrity within the clouds.  (For an extensive discussion of cloud computing challenges and deployments, see The Alchemy of Creating Intelligence in “The Cloud”, by Mark Dangelo, October 2009). 

Data routing and storage within the cloud is one of the leading concerns facing publically provisioned cloud computing environments.  As the data is routed via a host of third-party, and country controlled telecommunication services, it can be exposed to fraud, corruption, sequencing challenges, and of course, privacy constraints. 

Additionally, given the types of interfaces and security mechanisms deployed across disparate computing platforms, the ability to introduce error and fraud has also increased when the flexibility of “pay-as-you-go” cloud computing is added.  Bottom line, there are exceptional benefits and values with cloud computing – but for today, organizations must consider exposure, risks, and consequences before placing mission critical or financial transactions over them.

The good news is that there are standards and practices that are being developed, which should be mentioned.  These include multiple standards from Object Management Group (OMG), Storage Network Industry Association (SNIA), Organization for the Advancement of Structured Information Standards (OASIS), and many others (for a comprehensive list see http://cloud-standards.org/wiki/index.php?title=Main_Page).

 

* * * * * * * *

 

As you can see, data integrity is a complex discussion that incorporates many horizontal and vertical disciplines in FMG’s, within computer science, auditing, and legal professions.  The final question that has yet to be asked is “How do I know if my organization has a data integrity problem?”  Well, if this is the first time you have asked that question for your enterprise….

 

For additional information and discussion on data integrity, please attend the “How Much Is Data Integrity Costing You?” conference session on April 26, 2010, 3:00 p.m., at the MBA’s National Technology in Mortgage Banking Conference.  For a complete list of session panelists and topic discussions see www.mbaa.org.

 

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