About this time last year, I started a discussion about business rules.
Recent experience has prompted me to re-open the discussion, as UK deposit takers seek to address a regulatory compliance requirement, namely to deliver a Single Customer View.
In the UK, if a bank fails (goes bust), eligible deposit holders are guaranteed their money back, up to a limit of £50,000. The term “eligible” is critical. The UK Financial Services Compensation Scheme (UK FSCS) requires UK deposit takers to build a Single Customer View (SCV), that identifies “eligible” deposit holders, and calculates their compensation entitlement.
Deposit Takers must “flag eligible accounts”, and provide “An explanation of any code or keys used internally by the deposit taker, so that the FSCS can easily identify which accounts are held by eligible claimants”.
The above sounds reasonable… So…. What is the UK FSCS business rule for determining “eligibility”?
In layman’s terms, personal customers (individuals) and small businesses are eligible for compensation.
I hope you’re still with me – because it gets crazy from here, as we attempt to find out the exact rules for eligibility.
I include a screenshot of just some of the rules as they were on Sep 6th 2010 (click to enlarge and read). Alternatively you may view the rules as they are today at: http://fsahandbook.info/FSA/html/handbook/COMP/4/2
I’ve worked in Data Management for almost 30 years, and I have seldom seen such gobbledygook. Hundreds of deposit taking firms are subject to this regulation, which they must implement by January 2011. Each one must wade through this gobbledygook, seeking to extract clear, measurable and testable business rules, capable of being implemented. This is an example of bureaucracy gone mad.
What you think?