Banking & Financial Services · Systems change under regulatory scrutiny
When a migration goes wrong, the regulator asks why.
UK regulators fined TSB £48.65m after its 2018 IT migration, finding the bank failed to organise and control the programme. Banks must now show they can stay within impact tolerances, and Consumer Duty asks whether customers get good outcomes. Whether staff can run the new system is part of that evidence. That's the part we fix.
The evidence
What the regulators expect
combined FCA and PRA fine for TSB's 2018 migration, which hit a significant share of its 5.2 million customers.
FCA, Dec 2022end of the transition period: firms must be able to stay within impact tolerance for important business services.
FCA operational resilience (PS21/3)Consumer Duty in force for open products. Closed products followed on 31 July 2024.
FCA PS22/9Failed to organise and control the IT migration programme adequately.
FCA and PRA, on TSB, Dec 2022
What your programme needs
Four things that decide whether it lands
Staff ready on every system they touch
Customer-facing roles often work across many systems at once.
We provideRole-based training that follows the real flow of work across systems, not one system at a time.
Remediation teams up to speed fast
Large agency teams join with little time to learn the process.
We provideOnboarding programmes and job aids built for fast ramp-up, with practice before live cases.
Training you can evidence
Auditors and regulators ask how staff were made ready.
We provideDocumented design, attendance and readiness records you can show.
New tools used the way they were designed
Detection and AI tools only help if people trust and use them correctly.
We provideSimulations and scenario practice for new tools, including AI-assisted ones.
Worked example
What we would do on a new platform rollout
- List every role and every system each role touches in a normal day.
- Find the hand-offs where errors and complaints start.
- Build practice cases on realistic, anonymised customer records.
- Test readiness by role before go-live, and keep the records for audit.
Done before
In an FCA-regulated bank
- A UK retail bank
financial systems learned by around 90 agency staff on a remediation programme. We rewrote the training and added the interaction design.
training extended to an overseas team through a full documentation package.
training design and simulations for an AI-assisted financial crime detection tool, years before ChatGPT.
Procurement
Simple to buy
Experienced Training Ltd. Fixed-scope packages or a statement of work.
Subcontract. We work under implementation partners and consultancies.
Sources: FCA: TSB fined £48.65m · FCA: operational resilience · FCA: PS22/9 Consumer Duty
Next step
Tell us what is going live, and when
Day rate or fixed-price project, quoted against scope.
Recruiters & delivery partnersChris Whitaker is available for contract programmes.
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