The client, an important Private Bank in Geneva, asked for BWS support to implement in parallel the new FINSA (Financial Services Act) and a new Avaloq logical model for Persons with active roles on accounts.
Those projects were showing relevant functional overlaps, with major risks identified both in the technical implementation and in the client contact needs, but with deadlines that were not allowing any replanning option.
The first objective was a detailed analysis of the impact of the new person model to the Bank operating model, switching from an “account –centric” view to a “person-centric” model. Special attention has been devoted to identifying the activities which could require contact the final clients, thus generating an additional phase, more business oriented, impacting potentially the overall technical project planning.
Following this initial analysis phase, the “focus areas” below have been targeted with our work:
• KYC questionnaire collection: end clients could be required to be contacted for additional data, signing new forms and documents,
• Client information and other personal attributes, with regard to FINSA: data migration from the old to the new model and the decision on the primary contact person could impact the application of the new regulation,
• Modelling of complex roles for External Asset Managers and complex structures could require some client’s decisions,
• Legal Reporting could also be affected, having the new model an impact on the Reporting Person.
Following this initial phase phase, BWS team moved to the design of the operating model, with the goal to select the most efficient options for the implementation of the agreed changes:
• minimizing the rework requested to Private Banking teams and to Client Administration team
• optimizing the client’s contact through the collection of all required information in one form
Leveraging on our templates and methodology, BWS helped the Bank in achieving the project goals within the deadline imposed by the entry into force of the FINSA regulation.
• new legal forms and changes to the account opening contracts were designed with the support the Legal and Compliance Department,
• Missing data in the existing client data base have been identified and a path to close the gap, minimizing the number of requests to be submitted to the clients, has been planned,
• Target processes, based on the new Person Model and integrated within the core banking application and third-party systems, have been designed.
• Training / coaching of the Front Office on new processes, in all bank branches, was held jointly with the Bank’s trainers, integrating the presentation of the new functions with the processes description.