Spreadsheet Risks in Banks

No other industry perhaps handles such large volumes of critical financial data more than the banking industry. For decades now, spreadsheets have become permanent fixtures in the front-line reporting tool sets of banks, providing organised information when and where needed.

But as banks enter into a period of heightened credit risks, elevated levels of fraud, and greater regulatory scrutiny, many are wondering if continued reliance on spreadsheets is a wise decision for banks today.

The downfall of Lehman Brothers which eventually led to its filing for Chapter 11 bankruptcy protection on September 15, 2008, served as a wake up call for many institutions across the globe to make a serious examination of their own risk management practices. But would these reforms include evaluating the security of user developed applications (UDAs), the most common of which are spreadsheets, and putting specific guidelines as to when they can – or cannot be – used?

Banks and Spreadsheet Use

Banks have been known to utilise spreadsheets systems for many critical functions because most personnel are well-acquainted with them, and the freedom of being able to develop customised reports without needing to consult with the IT department offers flexibility and convenience. In fact, more than having a way to do financial budgeting and analysing customer profitability, even loan officers and trade managers have become reliant on spreadsheets for risk management reporting and for making underwriting decisions.

But there are more than a few drawbacks to using spreadsheets for these tasks, and the sooner bank executives realise these, the sooner they can adopt better solutions.

General Limitations

Spreadsheets are far from being data base systems and yet more often than not, they are expected to act as such, with figures constantly added and formulas edited to produce the presumably right set of reports.

In addition, data integrity is always a cause for concern as most values in spreadsheets are entered as manual inputs. Even the mere misplacement of a comma or a negative sign, or an inadvertent ?edit? to a formula can also be a source of significant changes in the outcome.

Confidentiality risk is also another drawback of the use of spreadsheets in banks as these tools do not have adequate?access controls to limit access to only authorised individuals. Pertinent financial information that fall into the wrong hands can lead to a whole new set of problems including the possibility of fraud.

Risks in Trading

For trading transactions, spreadsheets can prove to be of immense use – but only for small market volumes. As trade volumes increase and the types vary, spreadsheets are no longer a viable solution and may likely become more of a hindrance, with calculations taking longer in the face of bigger transaction amounts and growing transaction data.

And in trading, there is always the need for rigorous computational functions. Computing for the Value at Risk (VaR) for large portfolios for instance, is simply way beyond the capabilities of spreadsheets. Banks that persist in using them are increasing the risk of loss on those portfolios. Or, they can be opening up?opportunities for fraud?as Allied Irish Bank (in the case of John Rusnak – $690 million) learned the hard way.

Risks in Underwriting

Bankers who use spreadsheets as their main source of information for underwriting procedures also face certain limitations. Loan transactions require that borrowers? financial data be centralised and easily accessible to risk officers and lending officers involved in making decisions. With spreadsheets, there is no simple and secure way of doing that. Information can be pulled from different sources – individual tax returns, corporate tax documents, partnership documents, audited financial statements – hence there is difficulty in verifying that these reports adhere to underwriting policies.

Spreadsheet control and monitoring

Financial institutions which are having difficulty weaning themselves from the convenience and simplicity that spreadsheets offer are looking for possible control solutions. Essentially, they want to find ways that allow them to continue using these UDAs and yet somehow eliminate the?spreadsheet risks?and limitations involved.

Still, the debate goes back and forth on whether adequate control measures can be implemented on spreadsheets so that that the risks are mitigated. Many services have come forward to herald innovative solutions for better spreadsheet management. But at the end of the day, there really is no guarantee that such solutions would suffice.

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What Is Technical Debt? A Complete Guide

You buy the latest iPhone on credit. Turn to fast car loan services to get yourself those wheels you’ve been eyeing for a while. Take out a mortgage to realise your dream of being a homeowner. Regardless of the motive, the common denominator is going into financial debt to achieve something today, and pay it off in future, with interest. The final cost will be higher than the loan value that you took out in the first place. However, debt is not limited to the financial world.

Technical Debt Definition

Technical debt – which is also referred to as code debt, design debt or tech debt – is the result of the development team taking shortcuts in the code to release a product today, which will need to be fixed later on. The quality of the code takes a backseat to issues like market forces, such as when there’s pressure to get a product out there to beat a deadline, front-run the competition, or even calm jittery consumers. Creating perfect code would take time, so the team opts for a compromised version, which they will come back later to resolve. It’s basically using a speedy temporary fix instead of waiting for a more comprehensive solution whose development would be slower.

How rampant is it? 25% of the development time in large software organisations is actually spent dealing with tech debt, according to a multiple case study of 15 organizations. “Large” here means organizations with over 250 employees. It is estimated that global technical debt will cost companies $4 trillion by 2024.

Is there interest on technical debt?

When you take out a mortgage or service a car loan, the longer that it takes to clear it the higher the interest will be. A similar case applies to technical debt. In the rush to release the software, it comes with problems like bugs in the code, incompatibility with some applications that would need it, absent documentation, and other issues that pop up over time. This will affect the usability of the product, slow down operations – and even grind systems to a halt, costing your business. Here’s the catch: just like the financial loan, the longer that one takes before resolving the issues with rushed software, the greater the problems will pile up, and more it will take to rectify and implement changes. This additional rework that will be required in future is the interest on the technical debt.

Reasons For Getting Into Technical Debt

In the financial world, there are good and bad reasons for getting into debt. Taking a loan to boost your business cashflow or buy that piece of land where you will build your home – these are understandable. Buying an expensive umbrella on credit because ‘it will go with your outfit‘ won’t win you an award for prudent financial management. This also applies to technical debt.

There are situations where product delivery takes precedence over having completely clean code, such as for start-ups that need their operations to keep running for the brand to remain relevant, a fintech app that consumers rely on daily, or situations where user feedback is needed for modifications to be made to the software early. On the other hand, incurring technical debt because the design team chooses to focus on other products that are more interesting, thus neglecting the software and only releasing a “just-usable” version will be a bad reason.

Some of the common reasons for technical debt include:

Inadequate project definition at the start – Where failing to accurately define product requirements up-front leads to software development that will need to be reworked later
Business pressure – Here the business is under pressure to release a product, such as an app or upgrade quickly before the required changes to the code are completed.
Lacking a test suite – Without the environment to exhaustively check for bugs and apply fixes before the public release of a product, more resources will be required later to resolve them as they arise.
Poor collaboration – From inadequate communication amongst the different product development teams and across the business hierarchy, to junior developers not being mentored properly, these will contribute to technical debt with the products that are released.
Lack of documentation – Have you launched code without its supporting documentation? This is a debt that will need to be fulfilled.
Parallel development – This is seen when working on different sections of a product in isolation which will, later on, need to be merged into a single source. The greater the extent of modification on an individual branch – especially when it affects its compatibility with the rest of the code, the higher the technical debt.
Skipping industrial standards – If you fail to adhere to industry-standard features and technologies when developing the product, there will be technical debt because you will eventually need to rework the product to align with them for it to continue being relevant.
Last-minute product changes – Incorporating changes that hadn’t been planned for just before its release will affect the future development of the product due to the checks, documentation and modifications that will be required later on

Types of Technical Debt

There are various types of technical debt, and this will largely depend on how you look at it.

Intentional technical debt – which is the debt that is consciously taken on as a strategy in the business operations.
Unintentional technical debt – where the debt is non-strategic, usually the consequences of a poor job being done.

This is further expounded in the Technical Debt Quadrant” put forth by Martin Fowler, which attempts to categorise it based on the context and intent:

Source: MartinFowler.com

Final thoughts

Technical debt is common, and not inherently bad. Just like financial debt, it will depend on the purpose that it has been taken up, and plans to clear it. Start-ups battling with pressure to launch their products and get ahead, software companies that have cut-throat competition to deliver fast – development teams usually find themselves having to take on technical debt instead of waiting to launch the products later. In fact, nearly all of the software products in use today have some sort of technical debt.

But no one likes being in debt. Actually, technical staff often find themselves clashing with business executives as they try to emphasise the implications involved when pushing for product launch before the code is completely ready. From a business perspective, it’s all about weighing the trade-offs, when factoring in aspects such as the aspects market situation, competition and consumer needs. So, is technical debt good or bad? It will depend on the context. Look at it this way: just like financial debt, it is not a problem as long as it is manageable. When you exceed your limits and allow the debt to spiral out of control, it can grind your operations to a halt, with the ripple effects cascading through your business.

IT Risk and Control Solutions Specialists – Why you need them more than ever

Over the years, the capabilities of IT systems have certainly grown by leaps and bounds. But so have the risks that accompany them. Countless threats to IT systems now exist that are capable of seriously disrupting business operations. That’s why companies have to conduct assessments aimed at making sure their systems are still capable of functioning effectively, efficiently, and securely all the time.

If you think you’ve been lucky enough to be spared from these threats, then maybe it’s because you haven’t conducted a risk assessment on your IT system recently. All too often, we hear of CIOs who believed their IT system was in tip-top condition, only to be later caught off-guard by a critical system breakdown that would eventually cripple their business for days or weeks.

More information assets to look after

If, before, you only had to worry about regular office applications, workstations, a LAN and a server, today’s varied and more sophisticated information assets are more challenging to maintain.

In addition to network operating systems, database management systems, content management systems, email systems, virtualization platforms, document management systems, business intelligence applications, and accounting software, a typical enterprise may also have to look after firewalls, intrusion detection systems, storage and backup systems, and data loss prevention systems, to mention a few.

These understandably require the services of experts spanning a wide range of skill sets.

Rising threats to corporate identity and privacy

Individuals are no longer just the ones being preyed upon by identity thieves. Businesses can now be subject to corporate identity theft as well. You could wake up one day finding your business already accused of carrying out illegal activities, a big chunk of your money gone, and your directors? seats already occupied by complete strangers.

To make things worse, corporate threats aren’t just coming from the outside.

Threats to corporate privacy, for instance, can come from within the organisation itself. Sensitive information like trade secrets and financial data are often leaked out (purposely or inadvertently) by employees. This is largely caused by the ever growing number of options for communications and transferring data (e.g. emails, instant messaging, blogs, social networking sites, ftp, P2P, etc.).

Greater challenges in designing, developing, and implementing policies and programs

Laws and regulations like SOX and Solvency II, which have direct impacts on IT, are on the rise. That is why corporate policies and programs now require sweeping changes. You now have to be more deliberate in integrating IT when establishing governance, internal controls, change management, incident management, and performance management.

A solid understanding on widely accepted frameworks and good practices like COBIT, COSO, and CMMI will help you considerably in such undertakings. Using these frameworks as guidelines will not only help you keep your policies and programs attuned to the times, they will also keep you in compliance with regulations.

Increasing demand for disaster recovery and business continuity capabilities

Every time you have a down time, you increase the probability of losing your customers to competitors. The longer the down time, the greater that probability becomes. Therefore, when a major disruption strikes, you should be able to recover at the soonest. If possible, you should be able to deliver products and services as usual.

This of course requires spending to increase your disaster recovery (DR) and business continuity (BC) capabilities. Are you ready for it? Migrating your IT infrastructure from traditional systems to the latest technologies that are better equipped for BC/DR requires careful planning and implementation to ensure an optimal return on investment.

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Disadvantages of Spreadsheets – Obstacles to Compliance in the Healthcare Industry

Most of the regulatory compliance issues we talked about concerning spreadsheets have been related to financial data. But there are other kinds of data that are stored in spreadsheets which may also cause regulatory problems in the future.

In the US, a legislation known as HIPAA or Health Insurance Portability and Accountability Act is changing the way health care establishments and practitioners handle patient records. The HIPAA Privacy Rule is aimed at protecting the privacy of individually identifiable health information a.k.a. protected health information (PHI).

Examples of PHI include common identifiers like a patient’s name, address, Social Security Number, and so on, which can be used to identify the patient. HIPAA covers a wide range of health care organisations and service providers, including: health plan payers, health care clearing houses, hospitals, doctors, dentists, etc.

To protect the confidentiality, integrity, and availability of PHI, covered entities are required to implement technical policies such as access controls, authentication, and audit controls. These can easily be implemented on server-based systems.

Sad to say, many health care organisations who have started storing data electronically still rely on spreadsheet-based systems. Those policies are hard to implement in spreadsheet-based systems, where files are handled by end-users who are overloaded with their main line of work (i.e. health care) and have very little concern for data security.

In some of these systems, spreadsheet files containing PHI may have multiple versions in different workstations. Chances are, none of these files have any access control or user authentication mechanism whatsoever. Thus, changes can easily be made without proper documentation as to who carried out the changes.

And because the files are normally easily accessible, unauthorised disclosures – whether done intentionally or accidentally – will always be a lingering threat. Remember that HIPAA covered entities who are caught disclosing PHI can be fined from $50,000 up to $500,000 plus jail time.

But that’s not all. Through the HITECH Act of 2009, business associates of covered entities will now have to comply with HIPAA standards as well. Business associates are those companies who are performing functions and services for covered entities.

Examples of business associates are accounting firms, law firms, consultants, and so on. They automatically need to comply with the standards the moment they too deal with PHI.

Spreadsheet Risks in Banks

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Technical Debt Definition

Is there interest on technical debt?

Reasons For Getting Into Technical Debt

Types of Technical Debt

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