If there’s a common theme in progressive and busy legal departments these days it’s tackling time-consuming manual tasks and using technology to free up valuable lawyer time.
Recently, the BMO Legal and Compliance Group pursued an innovative approach to testing compliance with regulation, a required exercise for the bank that requires significant resources.
The BMO Legal and Compliance Group decided to automate certain testing activities through “robotics process automation” code that mimics the keystrokes of a human tester, reads content of documents, consolidates information and assesses compliance with regulations. Automation of these manual and repetitive activities increases efficiencies and reduces risk.
“Robotics is a really scary word and it makes people nervous, but this technology has existed for a really long time and what we were trying to do was find a new way to make it work for us,” says Candace Seton-Rogers, director of compliance, testing and practices at BMO.
Seton-Rogers’ team heads up the central methodology that compliance follows when conducting risk assessments and testing, as well as doing an independent compliance testing function.
“Robotics process automation is really just the automating of a process that was manual. We did a pilot of this technology in 2017 — what we were trying to prove is that we could take a very manual process that involved a person and took quite a long time and simplify it. With a person doing it, they would have to log on to many different systems, review documentation, glean different information and determine whether we were compliant with the regulation,” says Seton-Rogers. “We were able to prove this could be done in a matter of seconds by automating that process.”
The team was focusing on very manual tests in nature and settled on “Regulation B” — a consumer protection regulation in the United States. Based on the success of the pilot project, they decided to go ahead and implement the automated process for testing of Regulation B.
“As compliance professionals, we wanted to be seen as value adding and not just value protecting,” says Seton-Rogers. “Employing these tools really enables us to place less of a burden on the business and glean important information for senior management about how the customer experience is going,” she says. “We’ve seen from testing that it takes less of a burden on the first line, that we’re able to increase our efficiency and our scope of testing so we can test faster and the people who are our testers can apply themselves to more complicated analytical problems.”
The initiative is important to BMO’s Enterprise Compliance Program because it drives efficiencies, reduces risks and provides valuable insights across the businesses and second lines of defence.
The pilot produced learnings both from compliance with the requirements programmed and an understanding of the customer experience.
By adding the robotic component to BMO’s Enterprise Compliance Program, it achieved three things:
1. Decreases the burden for the business to support testing activities;
2. Empowerment of compliance experts to focus on areas requiring higher complexity analysis;
3. Strengthens testing capacity and capabilities. Testing informs the other parts of the program such as the risk assessment process and issues management.