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Banking

WHAT IS MODELOPS – AND WHY SHOULD BANKS CARE?

Paul Jones, Head of Technology at SAS UK & Ireland

 

Does your bank manager know who you are? Unless your net worth is unusually high, the answer is probably no, and that’s been the case for many years. Banks have been using statistical models to inform credit-related decisions since at least the 1970s, and today almost every aspect of operational decision making is driven by sophisticated real-time analytics. So, while customers may hear about the outcome of their loan application from a bank employee, the decision itself has already been made in the background by computers without any human input.

Model-based automation has unlocked huge benefits for banks and customers alike because credit decisions can now be made in minutes or seconds, rather than hours or days. However, managing models at scale creates significant challenges of its own, and designing efficient model operations (ModelOps) is still largely an unsolved problem for most financial institutions.

 

Big banks, big problems

For example, the more established banks tend to have adopted model-based approaches piece by piece over the years. The use of models now extends far beyond the retail credit risk marketing function, and different parts of the business are using different methodologies, tools and techniques for managing the model life cycle. Both the data and the models themselves are isolated in departmental silos, so the bank often ends up making decisions in unconnected ways or based on only a fraction of the information it possesses on each customer. In simple terms: If the mortgage department’s model doesn’t have the same information as the loan team’s model and isn’t aware that a customer just took out a large loan, it may not make the best decision.

Similarly, the size and complexity of these banks tend to sap the agility of their model deployment processes. Going live with a new model involves surmounting countless organisational and regulatory hurdles. SAS research indicates that it can take three months to get a model deployed, while Gartner has found that over 50% of models never make it into production. The opportunity cost of failing to have the right models in place can be significant. I recently spoke with a CRO who estimated that during the credit crisis in 2007, delays to model deployment had cost the CRO’s bank around £500,000 per month.


New challengers, same old issues

The newer digital banks and fintechs tend to do better at agile model management. Since the burden of legacy systems doesn’t apply, they can potentially start from scratch and adopt a more joined-up approach. And because they have fewer customers and their failure poses less of a systemic risk to the economy, they attract less scrutiny from regulators, which means they can have lighter processes.

However, as these smaller banks grow, the weight of regulation they must shoulder will grow too – a burden they may lack the infrastructure and expertise to sustain. While they may currently be able to get away with a simpler approach to model management, that’s not going to work in the long term. To compete at the scale of the larger incumbents, they will need to tighten up their governance and industrialise their processes.

 

Model management as a key battleground

Whether the established banks maintain their dominance or the challengers prevail, ModelOps will play a key part in shaping the industry over the next few years. As artificial intelligence opens up new possibilities for even smarter cross-channel, real-time decisioning, the ability to design, train, deploy, monitor, update, audit and explain models will separate the wheat from the chaff.

Currently, almost all banks are struggling with model life cycle management, and especially with deployment. A recent McKinsey study found that less than 6% of companies had the ability to easily embed AI into formal decision making and execution processes, and less than 15% had the technological infrastructure to support deployment. This jibes with a recent article where Gartner Vice President and analyst Jim Hare stated: “Where organizations need help is how do [they]scale and operationalize and really handle an increasing number of models in production.”

At SAS, we believe that the inability to integrate analytic solutions into workflows and achieve front-line adoption is the No. 1 reason why data and analytics initiatives fail. That’s why we’ve concentrated efforts on industrialising the deployment of AI.

 

Why is model management so hard?

To start moving in the right direction, banks first need to understand the problem. Why are model management and deployment so hard? One of the biggest reasons is more human than technical: It’s is a place where two different traditions meet.

On one side, data science, which comes from an academic background and aims to turn groundbreaking research into game-changing business value. On the other, IT operations, which focuses on delivering reliable services within technical, regulatory and business constraints. These two traditions work in different ways, move at different speeds, and target different goals – so it’s not surprising that there’s often a clash of cultures.

 

How ModelOps can help

The promise of ModelOps is that it provides a robust workflow that acts like a set of intermediate gears between the data science and IT operations teams, enabling the smooth transmission of models from development into production while allowing both teams to work productively and at the right pace. By automating handoffs between teams throughout the model life cycle and providing end-to-end traceability and governance, a ModelOps approach can turn a misfiring modelling pipeline into a well-oiled machine.

At SAS, we’ve had firsthand experience of the challenges of moving to a ModelOps approach. We’ve always been both a data science company and an IT operations company, so we’ve had a foot in both camps for over 40 years. But it’s only relatively recently, with the maturity of cloud technologies and the widespread adoption of DevOps practices such a continuous integration and deployment (CI/CD), that we’ve really cracked the problem.

For example, we’ve learned how to use the cloud to break the model life cycle out of departmental silos and provide a commercial model that suits the experimental, fail-fast approach that data scientists need. Meanwhile, modern DevOps tooling provides common ground for data scientists and IT operations teams to collaborate effectively and ensure proper governance while managing models at scale.

 

Real-world results

We’re now applying the insight we’ve gained to help clients throughout the financial services sector adopt a ModelOps approach. For example, Covéa Insurance chose SAS to enable the deployment of complex machine learning models in a high volume real-time scenario, while Standard Chartered Bank gained more efficient model deployment in support of IFRS 9 and won the Asian Banker’s Enterprise Technology Implementation of the Year award. Find out more about ModelOps or take a deeper dive.

 

Banking

IMPROVING THE BANKING EXPERIENCE THROUGH INFORMATIVE AND ENGAGING VISUAL COMMUNICATIONS

Javier Lopez, General Manager Vertical Solutions, OKI Europe Ltd

 

Banks play an integral role in daily life. However, everyday opportunities such as attracting new customers into branches to open an account, or promoting new offers and services to existing customers, can be lengthy, expensive and cumbersome processes – especially when tailoring communications to the specific requirements of each branch, or differing customer needs.

Quickly creating and adapting in-branch visual communications to communicate and educate cost effectively while remaining on brand can be a challenge, especially for banks that have networks of branches and print their visual communications centrally or use third-party suppliers.

 

Building trust through signage

Visual communications can help build trust and satisfaction between you and your customers.  The ability to create and print personalised communications on demand can not only instil confidence in your brand, it can also offer the flexibility to quickly adapt to financial trends and fluctuations in interest rates. This is particularly important in today’s volatile market, so that you can keep your customers informed while remaining competitive.

Javier Lopez

Printing in-branch and on-demand is an immediate and cost-effective way for banks to communicate with customers. With the right printer on-site, branch staff can easily create and print signage and customer communications as well as everyday documentation to a professional quality as and when needed. This saves on the cost of third-party suppliers and eliminates lead times for essential signage.

The ability to print a comprehensive range of collaterals in-house including freestanding and hanging banners, posters, self-adhesive floor and window stickers, as well as personalised leaflets and direct mailers, can help keep customers informed about the latest services and offers. It can also be used to remind both customers and staff to adhere to social distancing guidelines. Furthermore, the same printer can be used for day-to-day documents such as personalised mortgage or loan offers.

 

A message that sticks

As the world adjusts to a new normality, OKI Europe Ltd recognises the challenges banks face when encouraging social distancing and has teamed up with Floralabels to offer free* social distancing media and artwork to create self-adhesive floor stickers that can be printed quickly and easily from an A3 colour printer such as the C800 Series.  Floor stickers can help ensure customers maintain safe distances while queuing at counters, kiosks and ATMs. The free stickers include self-adhesive floor circles (285 x 285mm) and rectangular floor banners in two sizes (215 x 900mm and 297 x 1,320 mm) with various designs and messaging options to choose from.

 

Achieving ROI with a do-it-all device

When it comes to printing in-branch, implementing a printer with unrivalled media flexibility will provide the best return-on-investment. Not only will the bank be saving on printing and delivery time and costs, it will also save on storage space or potential wastage as well as offering the flexibility to be more reactive to market trends in a timely manner.

OKI’s multi award-winning C800 Series A3 colour printer is designed to take up a minimal footprint and will supply everything from 1.3m metre hanging and freestanding banners to posters, self-adhesive floor stickers, window stickers, leaflets, flyers and much more on a diverse range of materials. Featuring OKI’s pioneering digital LED technology, the C800 Series delivers professional quality results, at high speed and on-demand.

Banks are vital to helping people and businesses prosper, supporting economic growth. Investing in cost-effective do-it-all devices that enable the fast rollout of eye-catching, professional quality collateral will help banks and their customers thrive.

 

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Banking

CONSEQUENCES & RISK EXPOSURE FOR NON-COMPLIANCE WITH PCI DSS FOR THE BANKING SECTOR

Narendra Sahoo,Founder and Director of  VISTA InfoSec

 

Introduction

Every day millions of people around the globe fall prey to cybercrimes. What makes it alarming is that majority of the data breach/theft is related to debit and credit cards. For these reasons, the PCI DSS standards were set in 2006 to strengthen information security and secure cardholder data. PCI DSS is a compliance requirement for all organizations and financial institutions including banks that deal with card transactions. As per the set guidelines, banks and other financial institutes are expected to have in place comprehensive internal controls, and security frameworks to safeguard sensitive data. Financial institutions heavily deal with millions of transactions daily, which is why it is an incredibly challenging task for them to secure transactions and cardholder data. For the amount of risk they are exposed to, the financial institutes are the most heavily regulated industry in the U.S. and around the world.

In this article today we have discussed how PCI DSS Impacts the banking sector and the risks they are exposed to for non-compliance.

PCI DSS Compliance in a Glance

Payment Card Industry Data Security Standard is the set of security standards administered by the PCI Security Standards Council and established by the top 5 credit card brands namely the American Express, Discover Financial Services, JCB International, MasterCard Worldwide, and Visa Inc. The Compliance Standard applies to –

  • Any organization or institute that deals (store, process, transmit) with credit cards including service providers.
  • Any organisation (service provider) whose functioning can affect the security of the Card Data Environment of another organization (Client of service provider)

The scope of compliance typically covers data security, security framework policies and procedures, network architecture, and software design. Financial institutions, including issuing banks, (banks that offer credit cards to customers) and acquiring banks (financial institutions that hold merchants’ bank accounts, receive payments through the card processors, and deposit funds on behalf of the merchants), merchants, and service providers who process, store, transact, or enter into a contract with the five-card brands are expected to be PCI DSS Compliant.

Impact of PCI DSS Standard on the Banking Sector

PCI DSS is a set of security standards that banks need to follow diligently to stay compliant. For millions of transactions that they undertake daily and the risk to which they are exposed, requires them to have in place strong security measures to safeguard Cardholder data. Given below are some PCI DSS Standard Requirements that banks are expected to follow and security tests they need to perform to ensure no compromise of the cardholder data environment.

  • Test the defense systems in place to ensure network, end-point, and web applications are secure.
  • Frequently commissioning a controlled data breach attempt against the bank network to secure networks (Penetration Testing or even a Red Team assessment).
  • Perform security tests to detect known vulnerabilities like SQL injection, OS command injection, Cross-site scripting, broken authentication, etc.
  • Test networks and check for the presence of authorized and unauthorized wireless access points every quarter.
  • Perform Penetration Test on the cardholder environment (CDE) and systems and networks connected to it at least once a year or after a signification change has been made to the application.
  • Conduct a VAPT test to identify all possible threats and exploit them to penetrate the system at the application and network level.
  • Issues identified should be corrected and re-tested until the time systems and networks are clean and have strong defense systems in place against malicious activities.
  • Conduct Internal audits as per the PCI DSS requirements atleast once a year or after any major change to processes or systems.
  • Internal awareness training for the employees atleast once a year.

While it extremely challenging to meet the testing requirements of PCI DSS, performing the test and securing systems and networks is mandatory for Banks and other financial institutions. Failure to comply with the bank will have to face severe repercussions in terms of huge penalties, and loss of trust and credibility. We have listed below some serious repercussions and risks banks may be exposed to for non-compliance with PCI DSS.

Consequences and Risk Exposure to Non-Compliance with PCI DSS for Banking Sector

The risk of merchants suffering a data breach has far greater, implications and consequences, resulting in monetary penalties and often, irreparable damage to brand reputation.

Data theft & Security Breach-

Being non-compliant to the PCI DSS Standards simply means the bank may not have the necessary security measures in place to protect data. Having no strong defense systems and security built around the network and systems will lead to a security breach and data theft. This could further have huge financial implications on the institute, leading to huge losses.

Hefty Penalties

Non-compliance to PCI DSS can result in huge penalties ranging from $5,000 to $100,000 per month by the credit card companies. The penalties levied shall depend on the volume of transactions, and the degree of non-compliance. Further, the penalties levied shall be based on the discretion of the payment brand and the brand may decide to levy penalty based on per record that has been breached Moreover, the fines get reassessed monthly and may raise over time until the merchant achieves compliance. However, fines that the bank incurs can be passed to the merchant via high transaction fees or service charges if in case the merchant is found to be non-compliant. This will further strain or affect the relationship between the bank and the company.

 Compensation costs for non-compliance

A huge amount of compensation costs would involve in case of non-compliance to PCI DSS Standards.   The banks or merchants will have to probably compensate the clients with credit card monitoring, identity theft insurance, or in any other form of compensation.

Tarnished Reputation due to non-compliance

Security breaches and data theft shall not just have financial implications but will also cause irreversible damage to the reputation of your brand. Once your security is compromised, it will be very difficult to regain their trust in your bank. The image and reputation of your bank will be at stake and greatly tarnished if found non-compliant and face a security breach.

Revenue loss

Once there is a blot on reputation, it will significantly impact the business revenue and sales. There is a huge possibility of the bank facing loss due to an incident of a breach. Infringement can lead to loss of consumers, followed by loss of revenue. The financial implications are far more significant than the amount of money it would probably take to ensure compliance with PCI DSS.

Direct Intervention of Regulatory Bodies-

Non-compliance to PCI DSS followed by a security breach could call for the direct intervention of Regulatory Bodies and involve frequent Federal Audits. This would further involve imposing strict regulations and penalties. Consequences like this could severely impair the banking business.

 

Conclusion

The bottom line is that no matter how strong your defense is and the number of assessments you conduct, it just needs one slip for the breach to happen. So, no system is totally impenetrable, but at the end of the day, incase of breach, you need to present your bank in a way that it has followed all the compliance requirements and did its best to secure the systems to the best of its knowledge and ability.This is where the banks need to work on by conducting due dellligence as detailed in the standard and summarized above in the article.

Moreover, we belive  complying with the security standards is extremely important not just for the banking business, but also for the safety of their clients. While the standard requirements and testing process may seem to be rigorous, but the consequences of non-compliance can be destructive for the banking business. Banks in general have their take on the set standards. Depending on the risk levels (which are often high in the banking sector) and exposures, banks generally balance between the cost, security, and functionality, while investing in an effective security control framework.

 

Author Bio: Narendra Sahoo (PCI QSA, PCI QPA, CISSP, CISA, and CRISC) is the Founder and Director of VISTA InfoSec, a global Information Security Consulting firm, based in the US, Singapore & India. Mr. Sahoo holds more than 25 years of experience in the IT Industry, with expertise in Information Risk Consulting, Assessment, & Compliance services. VISTA InfoSec specializes in Information Security audit, consulting and certification services which include GDPR, HIPAA, CCPA, NESA, MAS-TRM, PCI DSS Compliance & Audit, PCI PIN, SOC2, PDPA, PDPB to name a few. The company has for years (since 2004) worked with organizations across the globe to address the Regulatory and Information Security challenges in their industry.  VISTA InfoSec has been instrumental in helping top multinational companies achieve compliance and secure their IT infrastructure.

 

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