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
examination-related records and assists with long-term access to electronic records. The records management functions are automated so they apply existing records retention and records management policies to electronically stored records. WISDM assists with providing timely electronic records responses to discovery or congressional inquiry, allows suspension of relevant documents and records, and disposes of final records in compliance with the Records Retention Schedule.
Until now, the only option was to print and file records. For those using it, the system fills the business need for compliant electronic document and records management, and improves access to information in the system. The OCC has also used the technology to standardize and streamline supervisory business processes, effectively increase security of electronic bank and supervisory documents and records, and improve collaboration and sharing between the community of examiners and supervisors.
Why WISDM Worked
The success of the system falls under four key areas:
1. Cross-functional sponsorship and management: The OCC had sponsorship of three OCC divisions: Large Bank Supervision, Office of Management and OCIO. Constant, active senior leadership - including the agency's CIO - provided ongoing support. A close collaboration between IT, Records Management and the LBS business units continued throughout the design, development and implementation processes. Additionally dedicated resources with appropriate and necessary technical and business-oriented skill sets were assigned to WISDM and development was appropriately scoped.
2. Industry-standard software: The OCC chose an industry-standard, DoD 5015.2-compliant tool that provided full document and records management functionality with very little customization.
3. User-initiated requirements: The OCC had an active and involved user group to assist with the development and validation of requirements. Additionally end-users we offered technical change management and opportunities to provide input at certain times throughout the system's development. The OCC could not have built the system it has today without end-users' help.
4. Sustained cultural change management: Early in the project, the OCC implemented an ongoing change management effort to promote adoption and ownership of the system. It also continually analyzed barriers to change and attempted to mitigate them. The OCC worked hard to ensure user concerns were appropriately communicated. Finally it made full use of change agents (e.g., training champions) to "cascade" change through the organization.
Of course, there are many lessons to be learned. The joint team learned to collaborate and build solid relationships among key project leaders. From the project's onset, it established and agreed upon clear roles and responsibilities for key project leaders.
For a project of this scope, the OCC needed to develop and adhere to a scheduled, structured methodology for system development. This was much easier said than done; it proved to be an extremely difficult feat. It's important to not underestimate the amount of planning time required.
The OCC also learned to manage its risk appropriately, while clearly defining the procedures for escalating risks to appropriate stakeholders. It's imperative to clearly state the impact of risks on the schedule, costs and product quality. The OCC tried to catch and resolve issues before general deployment. Even though the system is now in production, risk management continues to be ongoing and important.
Scope management was another key lesson the joint team took away from this project. Technical and functional requirements must be specific, testable and measurable. The OCC built a bite-sized piece, keeping the end goal of enterprisewide use in mind. Be realistic about what can be reasonably implemented and absorbed by your target user community. Recognize that new issues will continue to arise - work them into a requirements management plan and into ongoing development.
Last but certainly not least, the OCC learned that involving stakeholders early and often is truly a key. Understand and address their needs and comfort levels long before system deployment. Provide frequent opportunities for feedback on prototypes and requirements documentation.