talent supply chain management for a new financial landscape
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1 kellyservices.us talent supply chain management for a new financial landscape Know Your Vendor By Ben Decker 1
2 Contents 1 Introduction 2 Know Your Vendor 3 Background 4 Risk management 5 Rightsizing 6 Risk monitoring 7 Solution 8 Shifting landscape 9 Conclusion Terms FATCA GFC GRC KYV MiFID OCC OTC TSCM Foreign Account Tax Compliance Act Global financial crisis Governance, risk, and compliance Know Your Vendor Markets in Financial Instruments Directive Office of the Comptroller of the Currency Over-the-counter derivatives Talent supply chain management
3 This regulatory era in banking, financial services, and capital markets is unprecedented in modern times. The reaction to the global financial crisis (GFC) has no peer in the past 75 years. On the surface, the goals of recent regulatory mandates in banking and financial markets are relatively simple: minimize systemic market risks, and improve transparency with major banking operations. introduction The downstream impacts of these goals include enhanced governance, risk, and compliance (GRC) processes; workflow improvement in public/private market structures; and the pricing of certain complex and formerly bilateral financial products, such as swaps. Today, improving the operations transparency of financial services firms is expanding to include talent supply chain management (TSCM) through a new category of guidelines called Know Your Vendor (KYV). It seems that simplicity never lasts for long. The alphabet soup of new regulations and guidelines in the U.S., Canada, and Europe, has been mind-numbing falling hardest on those financial firms that have since been designated as systemically important financial institutions. Other financial institutions that have become ensnared in this regulatory net include exchanges, clearinghouses, insurance companies, and even some larger asset managers. 1
4 Know Your Vendor New regulations that will ultimately impact banks include the Volcker Rule and Dodd- Frank reforms in the U.S., the Markets in Financial Instruments Directive (MiFID) in Europe, and the Basel Accords. The Volcker Rule alone could cost U.S. banks an estimated $6 billion in lost revenue due to significant curbs on proprietary trading. And new over-the-counter (OTC) derivatives rules for clearing could ultimately force counterparties primarily banks to post as much as $2 trillion in new collateral. Coupled with the impending Basel leverage and liquidity requirements, bank balance sheets are no longer the elastic, seemingly infinite sources of business expansion that they once were. The net impact is the mass re-architecting of global financial markets and rightsizing of financial institutions business models. In general, this means fewer full-time employees and an increase in contractors and temporary staff. It also means less proprietary technology development and more managed service providers. In other words, business models need to minimize fixed costs, become much more flexible, and yield better outcomes. Moving the line between what is owned and what is managed is the essence of what is going on. In this context, the spotlight on TSCM is becoming brighter. 2
5 New OTC derivatives rules for clearing could ultimately force counterparties primarily banks to post as much as $2 trillion in new collateral. Enter KYV. Like the enhanced transparency, risk management, and client service outcomes from Know Your Customer, and the Foreign Account Tax Compliance Act (FATCA), KYV is among the newest additions to the regulatory alphabet soup. KYV is intended to apply similar rigor as Know Your Customer to vendor, supplier, and certain aspects of human capital management namely TSCM. Background In a bulletin published by the U.S. Office of the Comptroller of the Currency (OCC) on October 30, 2013, OCC Bulletin offers CEOs and Chief Risk Officers of U.S. national banks and federal savings associations new risk management guidance for third-party relationships; the bulletin also spoke to technology service providers. Whether they perform an activity internally or through a third party, expectations were set for banks and savings associations to practice effective risk management although the use of a third party does not absolve senior management or board members from ensuring the effectiveness and compliance (with applicable laws) of these risk management duties. 3
6 Prevailing cost structures are unsustainable given the prevailing and persistent landscape of business opportunities. Risk management For banks, the new KYV risk management processes should: Be commensurate with the complexity of its third-party relationships Ensure comprehensive oversight of critical activities Be performed throughout the life cycle of the relationship, including: - Impact on bank strategy, inherent risks of the third-party activity, selection and due diligence process, written contracts, monitoring, contingency planning, oversight, independent reviews, and documentation In other words, the implementation of this KYV directive is extremely complex particularly when taken in the context of all the other transformative mandates and directives that have left virtually no corner of banking operations untouched. Consider the nature of the banking landscape and the resulting changes in banking business operations. Where pre-2008 banking generated a lot of revenue, regulatory drivers and other significant factors are changing markets and businesses. Another consideration is the impact of disruption from digital-era upstarts and giants that threaten to offer competitive solutions for previously sacred business lines, such as payments, lending, debit cards, and investment advisory. 4
7 In response, banks and other large financial institutions are engaged in a multi-year rightsizing exercise. This could involve reductions in non-essential headcount and lower performance business activities the stuff that will not be replaced. In many cases, employee headcount is reduced in favor of temporary staff and consultants, and moving tasks, workflows, and even entire business lines (technology and all) into managed services arrangements. Rightsizing The savings from overinvestment in non-essential activities has already been realized; the low-hanging fruit has been cut and picked. Remember, we are in year five of an unprecedented market transformation that is expected to reverberate for several more years, and maybe even decades. In order to continue to tighten belts to survive the sheer duration of this rightsizing period, banks are now forced to cut further into muscle, i.e., complex operational components. 5
8 Risk monitoring At the same time, the cost of all operations proprietary or outsourced is incrementally increasing relative to the pre-gfc period because of new and additive GRC initiatives, like KYV. Moreover, given that U.S. regulators and legislators have taken a leading role in the crafting and implementation of the G20 Development Commitments 1, the global equivalent of KYV and many other regulations will eventually compound the complexity of ongoing implementation and maintenance of these new programs. These are all relatively simple concepts to comprehend for senior management within financial services. It makes sense that more rigorous risk monitoring and oversight processes be developed and/or re-engineered for the foreseeable environment as such processes may not have existed before. After the fact, it will likely be forgotten that it took a regulatory nudge to build these programs out. They will eventually prove valuable to improved performance of banks and bring incremental safety to the financial landscape. Effectively and efficiently implementing these directives is an entirely different story. Banks with global operations and product diversity are among the most complex business entities on the face of the planet. Changing them on a holistic or enterprise basis, during a period of rapid transformational ecosystem shifts, will confound even the brightest senior executives. 6 1 established at the 2009 G20 Pittsburgh Summit to coordinate national and regional responses to the crisis
9 Chances are, even the most nimble and advanced banking cultures will need a partner to support needed change with regard to TSCM. Talent supply chain management a reference to the changing contractual relationship between a bank and its human capital resources is incredibly important. Undoubtedly, the long-term result will be faster, smarter, more agile banking entities with enhanced offerings for their clients. These are the hallmarks of the more-for-less banking era that we live in today. Solution As banks migrate to a new operating model, the number and complexity of thirdparty relationships is swelling, and the spectrum of support they provide is going to become much broader ranging from the mundane and inconsequential to the critical and increasingly complex. Beyond bank functions or information technology operations, whole business lines are being targeted for moves into a managed services framework. As a result, the OCC and others are becoming increasingly concerned that the quality of risk management over third-party relationships may not be keeping pace with the level of risk and complexity of these relationships. 7
10 Shifting landscape Truth be told, many banks have already checked the box on enhanced vendor management programs. Many have already engaged third-party specialists to support the development, implementation, and management of these new programs. But then the landscape shifts: the regulators add a new wrinkle to the existing oversight and reporting requirements; the business mix shifts along demographic, geographic, or performance criteria; or, the new CEO or Chief Data Officer wants to establish a legacy in a new direction. In short, the idea that banks may not be keeping pace is ubiquitous. Therefore, the more-rapid-than-ever pace of change in banking and financial services today causes internal and third-party-managed programs to get stale very quickly. There is no way around that, so programs and partners need to stay fluid. Banks needs to reassess third-party service providers regularly, arguably on a biannual basis. Yes, it s more work. It s something else to worry about, and it adds to administrative burdens that are already heavy. But a more advanced cultural mindset ensures that programs are cutting edge, keeping third-party providers on their toes. The new norm is continuous improvement with greater process update frequency. 8
11 Close observers of banking and financial markets have yet to say that they ve seen a light at the end of the regulatory tunnel. The promise of an oncoming season of banking prosperity, comfort, and ease has yet to be seen. However, whether or not the financial landscape becomes easier again, banking operations need to become stronger, more transparent, and more agile. This is true of relationships, processes, technology, and data core components of a bank s value proposition. Conclusion Nearly a year since the KYV guidance was published, leading organizations continue to establish vendor management and governance boards, while also looking to external specialists in TSCM as a means to supplement and augment internal efforts. Meanwhile, the complexity of the managed services space itself is being pushed to new boundaries, and regulatory pressures are forcing both sides to mature faster. Ultimately, many who believed they were ahead of the KYV issue are now rethinking their strategy, and with good reason. There is a growing need for co-existence between the banks vendor management office or vendor governance board and their external TSCM providers. The two complement one another and are interdependent. Though banking, institutional capital markets, and other financial service offerings were relatively insular in the pre-gfc era with regards to operations, that model is no longer valid. Banks cannot dabble in outsourced functionality. Effective management of third-party relations is quickly becoming a competitive necessity. Make sure your talent supply chain management partners are delivering at the leading edge. 9
12 About the author Ben Decker serves as director & global workforce solutions consultant financial services and insurance for Kelly, with a special focus on financial services and insurance. As a strategic consultant, he is focused on identifying the workforce trends and labor supply/demand dynamics impacting these complex industries. Ben has spent the past 10 years of his career working for Kelly in areas of service, implementation, sales, and consulting. These experiences have helped him navigate solutions and services to meet unique client needs. Ben holds a Bachelor of Arts degree in business administration with minors in human resource management and economics from the Haworth College of Business at Western Michigan University. About Kelly Services Kelly Services, Inc. (NASDAQ: KELYA, KELYB) is a leader in providing workforce solutions. Kelly offers a comprehensive array of outsourcing and consulting services as well as world-class staffing on a temporary, temporary-to-hire, and direct-hire basis. Serving clients around the globe, Kelly provided employment to approximately 540,000 employees in Revenue in 2013 was $5.4 billion. Our finance specialty places professionals across corporate accounting, corporate finance, and financial services. Areas of expertise include: accounting, financial analysis, SEC reporting, payroll, internal audit, tax, corporate consolidations, budgeting, treasury, shared services support (accounts payable, payroll, and accounts receivable), and financial services (mortgage operations, trust accounting, investment analysis, treasury, and compliance). Want more information? Visit kellyservices.us today. All trademarks are property of their respective owners 2014 Kelly Services, Inc. Z1042A Supply #637 11/14 kellyservices.us
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