Established in 1863 as a bureau of the U.S. Treasury Department, the Office of the Comptroller of the Currency (OCC) charters, regulates and supervises all national banks and federal branches of foreign banks. Headquartered in Washington, D.C., the OCC has four district offices plus an office in London to supervise national banks' international activities.
The OCC has a staff of examiners that conducts on-site reviews of national banks and provides ongoing supervision. The agency issues rules, legal interpretations and corporate decisions concerning banking, bank investments, bank community development activities and other aspects of bank operations. With each on-site review, many documents and official agency records are created that must be properly stored and managed.
The Right Solution
Several business drivers led the OCC to search for an electronic document and records management solution that facilitates supervisory activities, search and retrieval, and recordkeeping requirements. First the Records Management Program Office needed a solution that would ensure the OCC's recordkeeping policy and records schedule are applied correctly and consistently, as required by law.
The office also needed the ability to locate electronic documents quickly and easily not only for requests from program managers and Congress, but also for Freedom of Information Act requests and legal discovery.
The complexity of large bank operations and the current regulatory environment also added to the OCC requirements to be included in a new system. The OCC's Large Bank Supervision (LBS) business unit needed better tools to standardize and streamline its business processes, increase the security of electronic bank supervisory data and documents, and improve collaboration and data sharing among examiners. The OCC's customers played a key role - several requested the option to submit documents in an electronic format. The OCC also would like to share information between federal financial regulatory agencies in the future.
The Records Management team and the LBS business unit collaborated with the Office of Chief Information Officer (OCIO) to implement a system over several years that would fit the OCC's needs. A holistic approach was employed during system development that integrated technology, processes and people to establish a scalable system suitable for eventual enterprisewide use.
A Phased Approach
The OCC chose a commercial off-the-shelf, Department of Defense 5015.2-compliant product from Open Text. The Workflow and Information Systems and Document Manager (WISDM) system offers a secure, central repository to store electronic examination information, applies consistent records retention and provides appropriate security across all documents. WISDM systematically manages the full life cycle of each document: from creation through business use, to approval as a record, through retention and disposition.
To ensure successful rollout and user acceptance, the joint team deployed WISDM in two phases with interim adjustments.
Phase one was a pilot deployment in July 2007 to approximately 50 users in two locations. The pilot proved to be a successful installation, and the OCC obtained valuable user feedback for the second phase. Phase two took place between September and October 2007 and involved approximately 575 users in 20 locations. After receiving system certification and accreditation, WISDM is now being used by two OCC business units: Large Banks Supervision and the Records Management Program.
Integrating with the OCC's legacy data management system and Active Directory, WISDM stores bank examination-related documents in a secure central repository, allowing users to locate documents and records though sophisticated search capabilities. Groups of people can store documents in a central location, describe them using consistent criteria and then locate them using those criteria. WISDM users can easily apply standard conventions for metadata, taxonomy and document naming. There are also standard templates for key documents with system interfaces to WISDM. Additionally the system uses role-based permissions and document classifications based on the business units' content security model.
From a records management perspective, WISDM manages bank