Let me put this even more bluntly: if your bank's technology plan isn't 99.5% about dealing with government regulation and maintaining core record integrity and auditability, you are not a serious player in the space.
Let me put this even more bluntly: if your bank's technology plan isn't 99.5% about dealing with government regulation and maintaining core record integrity and auditability, you are not a serious player in the space.
Everything was filtered through the lens of "What would the regulators say? And how do we tell the regulators what we're doing?"
You have lots of extra regulations for sure but most of them are about retention of financial records. If a system isn't processing/storing financial records or "privileged" information nobody gives a damn.
The "technology plan" is 99.5% about making or saving money. That remaining .5%? Yeah, that's compliance. Because that's all it costs. Unless you think central logging systems are going to take up some large percentage of a multi-billion dollar quarterly budget?
People love to complain about "the costs of regulation" but you know what? In finance it really doesn't amount much in terms of "how much we spend." How much "it holds back the market" is a different debate entirely.
Aside: Without those regulations we'd just repeat all the same financial disasters throughout history.
So you tell me: what computer system of any import in a bank doesn't touch one of these three things?
They really don't care about systems that don't process financial information! They don't care about your dev or qa environments. They don't care about your DNS servers or your switches or much else for that matter.
Regulators are 100% laser-focused on financial information and transactions. They want to see ledgers and logs and they want to see evidence that your systems prevent tampering. That's it.
There's no financial regulators that actually audit IT stuff. We probably should have them but we don't. The closest is the FFIEC but they only publish non-binding guidelines.
If you think the PCI-DSS matters to banks you're mistaken. Every year we audit ourselves and put the results in a filing cabinet somewhere. We have no obligation to show it to anyone and no one would hold us accountable for failing to be PCI compliant anyway.
From experience, said process cost waaaay more than 0.5% of the budget. Time and cost overruns, massive overhead in personnel and a drain on mental resources which should have been spent on actual release quality rather than an audit trail meant to convey "Certified" quality. All in all, I'd say 50% of the costs of IT delivery were spent in plodding through the checkpoints with much of the other half being consumed by the interest on 20 years of technical debt accrued as a result of those very same resources being misdirected in such regulatory endeavours.
I recognise than I'm far too cynical to see regulation as anything other than a shield against liability. It's simply too obstructive to contribute to actual quality improvement. On the plus side, it does keep about 50% of IT personnel in a job.
So I guess you can count me in with the lovers :-)