Improving Compliance Sustainability with Business Performance Management
Executive Overview
Welcome to the decade of un-funded regulatory compliance mandates. Since the accounting scandals of Enron and WorldCom were made public and global responses from governing bodies have responded with burdensome and costly enterprise control requirements, firms have been struggling to determine the appropriate model for corporate governance. Specifically, firms have been considering the increased costs of demonstrating compliance to their auditors and regulatory agencies.
Many firms believe that technology can play an important role in compliance sustainability; however, it must be understood that technology alone will not ensure compliance. Technology must be interwoven into business processes to ensure that controls are compliant.
A Sarbanes-Oxley (SOX) compliance and governance solution requires a combination of business processes and technology, but to the pleasant surprise of many, much of this technology has already been acquired by the enterprise. Most enterprise applications, including enterprise resource planning (ERP), customer relationship management (CRM), enterprise content management (ECM), and supply chain management (SCM), play an important role in ensuring that controls are in place to demonstrate and sustain compliance. This includes role-based approval processes and auditable transaction flows. More recently, firms are turning to their business performance management (BPM) investments to understand how these enterprise applications can best be leveraged.
Enterprises must ensure that their financial business processes can meet the increasingly demanding compliance requirements worldwide. IT executives, in conjunction with CFOs, must therefore focus on achieving critical dimensions, such as communication, controls, records retention, risk and fraud prevention and transparency/visibility. In addition, they must evaluate current and potential future business applications against these capabilities. Financial reporting, consolidations, and business planning through BPM software can play an important role in ensuring this compliance. IT and finance executives should place these considerations at the center of their approach to BPM, to mitigate risks associated with non-compliance.
The key to any BPM approach to compliance is internal education, which must accompany the initiative. Education on how to understand and decipher financial results and variances, as well as how to approach an analysis is critical to a BPM undertaking to improve and sustain compliance. It is important to understand that compliance is not static. Rather, continuous business analysis is required to understand and probe results to ensure accuracy and consistency, as well as understand out-of-threshold conditions. This is not only a good compliance approach, but also good business sense and can ultimately lead to a more effective and competitive enterprise.
Business and Economic Drivers Creating a Need for a Sustainable Approach
The corporate finance organization is coming under increasing pressures, both internal and external, to add more value to the business. The CFO is being challenged with meeting shareholder's expectations while investing in the future of the business, containing and even reducing costs. RFG sees the following trends:
Increased focus on driving down costs and improving internal efficiencies for both enterprise and finance-specific business processes.
Cash-flow and balance sheet improvements, including working capital management, are taking higher priority in the enterprise.
Globalization is causing new challenges for enterprise financial processes.
Mergers and acquisitions (M&As) cause fragmented financial processes and systems that lack integration in supporting enterprise business processes. Many firms struggle with funding for common enterprise accounting solutions.
Regulations (including but not limited to SOX and International Financial Reporting Standards (IFRS)) demand consistent processes and strong internal controls.
Firms must have the ability/agility to address changes in legislative requirements as regulations are added and changed over time to respond to movements in public opinion or corporate responsibility. Companies will want a sustainable and compliance-proof applications platform.
Compliance is a major initiative for many enterprises worldwide. Most firms do not know where to start. In the first year of SOX compliance in the U.S., many companies spent heavily on services. Now, many understand the shortcomings of their financial management processes, and are wondering how to sustain compliance and replace some of the offline controls that they put in place to satisfy their auditors. RFG typically hears the following questions from finance and compliance executives in virtually all industries regarding compliance efforts:
Can technology improve our compliance approach?
Is there a way reduce process costs and develop a sustainable and cost-effective approach to compliance?
Is there a way reduce process costs and develop a sustainable and cost-effective approach to compliance?
Is it just about compliance? Can I achieve additional business value?
Where do I begin?
What are other companies doing?
Those regulations that create the most headlines have common themes, including ensuring accuracy in reporting and financial processes and data, security, auditability, and records retention. The most arduous of the compliance mandates include:
Basel II (Europe): Capital assessment and reporting standards for global banking.
Gramm-Leach Bliley Act (GLBA) (U.S.): Privacy of financial information.
Health Insurance Portability and Accountability Act (HIPAA) (U.S.): Right to carry insurance between jobs; privacy of patient information.
LSF (France): Requirements on disclosures to shareholders and the market for the purposes of corporate governance and internal control.
NASD 3110 (U.S.): Written policies and procedures for review of correspondence with the public.
EU Accounts Modernization Directive: Surviving European legislation and forerunner to the Operating Financial Review (OFR) in the U.K., stipulating the disclosure of information outside the traditional financially-oriented content of annual reports.
Uniting and Strengthening America by Providing Appropriate Tools to Intercept and Obstruct Terrorism (U.S.A. PATRIOT) Act: Customer documentation requirements in order to "know your customer."
(SOX Act of 2002 (U.S.): Fiscal accountability for all public companies.
U.S. Securities and Exchange Commission (SEC) Rules 17a-3 and 17a-4: All records related to securities transactions to be maintained for three years.
Making the matter more complex, firms frequently need to bridge multiple compliance efforts effectively across the enterprise. The ownership of these mandates tends to lay with multiple C-level executives throughout the firm. Compliance requirements have caused this to be the decade of unfounded mandates. Many firms had to redirect monies from other mission-critical projects to fund the soaring costs for resources to get the job done, including professional services around compliance to prepare for intense audits at the end of the fiscal year. Thus, compliance impacts the corporate culture, corporate policies and processes, the investment community, and stock price/valuation. The only thing certain about compliance is that there will be stricter enforcement and more regulation to come.
The most significant compliance mandate for most firms, particularly in the U.S., is SOX. Now in its second year of enforcement, this has been a major effort for most companies, and compliance to it does not come cheaply. For many, this incremental spending has made the difference between profitability and taking a loss for the fiscal year. The major culprit of the SOX act is Section 404, which requires firms to prove to their auditors through a lengthy process that they have financial controls in place in all business processes that impact enterprise financial management. Many firms have gone through a SOX 404 audit and experienced frustration at the significant spending for its preparation with assumed little business value or improvement derived.
Compliance and Spending
Compliance does not come cheaply, and many firms are struggling with maintaining an effective cost structure to support it. Some have added staff to make up for the auditability and controls that were lacking in their current platform of business processes and technology. For example, for companies facing year two of compliance with Section 404 of SOX, there is a continued outcry that the costs of complying are way out of line. In year one, based on conversations with RFG clients, auditors, and compliance service providers, RFG has found that enterprises are paying between $1 million and $3 million per billion dollars of revenue on consulting services. Yet, many of these same enterprises have failed to invest in software systems that would ease the burden of compliance in the future. © Robert Frances Group, Inc. 4
To date, much of compliance spending has been focused on business services to set up compliant processes, as well as programs to assess financial management processes for SOX Section 404. According to a March 2005 survey by Financial Executives International (FEI), companies' total costs for year one of Section 404 compliance averaged $4.36 million, up 39 percent from the $3.14 million they expected to pay, based on FEI's earlier July 2004 cost survey. FEI believes that this increase stems largely from a 66-percent leap in external costs for consulting, software, and other vendors. According to this survey, the total cost of compliance averaged $1.34 million for internal costs, $1.72 million for external costs, and $1.30 million for auditor fees. The auditor fees are in addition to companies' financial statement audit fees, and are on average 57 percent higher.
While the first year of SOX had many focus on what was required to demonstrate compliance to their auditors, savvy firms are now turning their focus to sustaining compliance and reducing some of the incremental costs that they incurred in year one. Out of that costly activity, a list of work items were developed that often proved to be additional opportunities for the services vendors to be addressed in the following year. For most firms, it is not just compliance to SOX that is at issue, rather developing an approach to the many regulatory compliance mandates listed above. Most of these cannot be addressed with a one-time quick fix; rather compliance needs to be demonstrated on an ongoing basis with sustainable compliance being the lofty goal.
SOX audits will become more difficult over the years, as enforcement is increased and more details are scrutinized. Fortunately, the trend towards better methods for simultaneously sustaining compliance and achieving a cost advantage is leading companies to improve poor financial consolidation and reporting practices. Moreover, because organizations are working to consolidate enterprise accounting information for both internal management reporting and external reporting, firms are beginning to view financial consolidations as a critical component of their performance management processes and solutions.
Enabling Compliance with Technology
Since 2002, many vendors have brought compliance solutions to the market that meet certain aspects of compliance controls. The market response to these tools has been interesting at best, with the majority of firms holding back on investments and dealing with year one of SOX compliance with a variety of inefficient (but potentially effective) manual processes. Often, these manually processes are augmented by spreadsheets or databases, such as Excel and Access from Microsoft Corp. With the dawn of this new compliance age, end-user organizations have been bombarded with marketing messages from most enterprise applications vendors on how their products support compliance. In addition, there has been the emergence of numerous applications that can assist in financial process management and compliance assertions.
Still, given all of this new and improved technology, many firms still perform management and financial reporting through their ERP general ledger (GL) solutions, such as those from SAP AG and Oracle Corp. Moreover, organizations that found areas of material weakness in year one addressed them primarily through manual processes and Excel-based workarounds. Some of these companies leveraged traditional business intelligence (BI) infrastructure to improve compliance (e.g., data warehousing, metadata management, and standard reporting tools). However, this does not go far enough to provide the required controlled process in an auditable solution for financial consolidations.
What is Business Performance Management?
BPM is the fastest growing segment of the BI market. BPM takes up where BI leaves off, and adds value to generic BI by providing the ability to effect change by delivering rich reporting and analysis to domain intelligent BPM applications, ensuring alignment of enterprise objectives.
BPM is a closed-loop process that bridges both technology and performance management business processes. It delivers business intelligent applications, and leverages BI platforms to provide a single repository to form the baseline of results and their enterprise-wide distribution. In BPM, there is an ultimate goal to tie together metrics, consolidation, reporting, strategy mapping, and planning/budgeting into a consistent framework. This framework is linked through unified business processes and workflow to ensure that validation, control, communication, and visibility are enabled to the appropriate management teams.
BPM offers the ability to effect change and improvements needed for consistency in financial reporting to the technology stack, including the following:
High-level enterprise business planning and forecasting
Lower-level enterprise budgeting and forecasting
Strategy maps that set metrics (targets and expectations) that are linked to business planning and reporting
Financial consolidations and reporting capabilities
Cost allocation and modeling capability and support for leading Six Sigma, Economic Value-Added, and Activity-Based Costing (ABC)/Management
Financial and operational process management to ensure the appropriate routing of financial issues and approvals
In addition, BPM combines these technological benefits with the foundational BI elements, including:
Common enterprise reporting and analysis tools capabilities
Common and consistent data that has been validated and controlled by the BPM process and made available to decision-makers across the organization
Tools to extract information from all required financial and operational solutions, commonly known as extract, transform, and load (ETL)
Dashboards and scorecards that present results
How Can BPM Improve Compliance?
Through a consistent approach to reporting, planning, metrics management, and financial consolidations, BPM solutions can enable improvements in the following areas that are critical for SOX and other compliance initiatives:
Visibility/Transparency: Many regulations require firms to improve their view into operations and enterprise processes. SOX Sections 302 and 906 require C-level sign-off on results, and Section 409 requires that firms have the insight into financial and operational results. This includes providing visibility and drill down, often across a multi-ERP environment. Inconsistency, and to a lesser extent fraud, can be reduced by enabling transparency, particularly through a Web browser or portal interface to ensure that the appropriate eyes are viewing the data. Unfortunately, many firms are extremely Excel-reliant for reporting, which adds to complexity in this area. Ideally, firms should source all of their financial and operational reporting from a consistent repository, such as a data warehouse or data mart, as well as utilize like reporting tools where appropriate, with the goal of providing "One Version of the Truth." In addition to results linkage, there can be linkage in the financial management processes that provide validity to the visibility and transparency.
Control: Many firms will reexamine the controls that have been configured into their ERP applications as well as BPM processes to ensure that role-based processes are controlled and have the appropriate access and security rights.
Communication: SOX compliance will require improved communications capability, and many firms will implement internal and external portals, content management processes, and e-mail-based workflows to enable this. Internal communication tools are necessary to facilitate the identification and resolution of changes in financial position (Section 409) as well as to coordinate the "official external response" to external parties through aggregation of data and content, including collaboration inherent in the BPM processes themselves.
Risk Management/Fraud Prevention: While there are many firms investing in governance tools to document and assess controls, many firms are also considering data-auditing/business assurance analytic tools in addition to BPM. Firms are usually these solutions to gain an understanding of risk areas, as data is bridged from one component solution to another.
Compliance and BPM Reporting
Financial accuracy has always been important; however, now CFOs are reemphasizing the need to make financial accuracy a top priority, and the BPM vendor community is rallying to this cause. SOX requires CEOs and CFOs to certify during periodic reporting (i.e., 10-K and 10-Q) that the information disclosed is in full compliance with the Securities Exchange Act of 1934. In addition, SOX requires them to ensure that the information fairly represents the company's financial condition and results of operations.
BPM platforms will prove to be instrumental in providing the following visibility/transparency, control, communication, and risk management capability:
Putting results in front of those that need to know: Through financially-focused portals and Web-based reporting tools, results details can be more accessible to those managers that can ensure results accurately represent operations. Firms should ensure that appropriate financial and operational personnel have visibility into financial management data, of course in a controlled and secure manner.
Flash reporting before month-end: Firms should not wait to month-end before they can view consolidated results. Flash reporting capability can prove invaluable to identify potential errors before the critical month-end book-close, where there may be limited time for analysis and correction.
Drill down on details and online analytical processing (OLAP): Analysis capability, including OLAP, is critical to provide visibility into transactions (or appropriate summarized details) that cause results anomalies. Drill down in a BPM environment is preferable over having to query multiple ERP solutions, often with different interfaces and reporting tools. This is an advantage due to the process controlling the activities and validity and trust of the data.
Identifying out-of-tolerance conditions and alerts: BPM tools can highlight key areas for analysis on under- or over-predefined tolerances associated with a financial or operational metric. This should take into account forecasting, trending, and modeling capability such that if a metric falls out of range of a trend or budget/plan, or the appropriate flag is raised, the workflow process gets the investigation underway.
Segmenting reporting into material/significant elements: Material items should be routinely investigated to ensure consistency during the month as well as at month-end. This may include a focus on billings to top customers, billings from top suppliers, top expense/capital items, as well as results from mission-critical business transactions.
Compliance and Financial Consolidation
Key among the areas in which firms can benefit from technology investments spurred by SOX 404 and other compliance-driven projects is financial consolidations. Over the past three years, the focus of most firms' BPM implementations has been on planning, internal reporting, and metrics management rather than on external reporting. As such, many reporting tools have been leveraged to meet this requirement.
Organizations will need an effective process to consolidate financial results and operational results from multiple solutions, including ERP systems. These often need to include ETL processes that translate multiple chart-of-accounts to standard, consolidated charts-of-accounts and product codes, since many firms are the product of M&As. This aggregation must enable the appropriate detail level to ensure financial audit/validation processes and external reporting while providing the easy ability to grow with the M&A activity in today's environment.
Although improving internal visibility should be at the center of any compliance initiative, a company must also pay close attention to external financial reporting and consolidations that go beyond the mere assembly and reporting of enterprise data. BPM has had an impact on the way firms spend on improving analytics, through a concerted effort between BI and financial analytics approaches.
Many RFG clients have spent heavily on planning and management reporting improvements. However, at the same time, they have maintained predominantly Excel environments for financial consolidations. To make matters worse, RFG has seen many multi-national firms with multiple installations of ERP solutions, and often from different providers. These firms are challenged to consolidate management and financial results, while ensuring consistency in financial data across the enterprise. This problem is further complicated when finance staff rely on offline processing in Excel and Access to accumulate data from multiple source systems and then rationalize it.
Ideally, firms should source all of their financial management reporting from a consistent repository linked to the BPM processes and seek to automate these allocations within a reporting tool. However, over the past year, workarounds in the area of financial consolidations have created greater dependence on Excel. Relying on these workarounds will ultimately prove more costly and less effective than an implementation of an auditable, centralized solution for financial consolidations.
Such a system can automate financial consolidations and reduce the amount of time needed to produce external financial statements such as 10-Ks and 10-Qs. Leading firms are implementing this type of software, then augmenting consolidation processes with both internally-facing and externally-facing portals. The portals can streamline financial statement preparation and provide information on required corporate disclosures, including director holdings/information/affiliations and changes in financial condition, as required under SOX Section 409.
Enterprises face many challenges during the financial consolidations process. These challenges represent major opportunities for error. As such, IT executives should consider purchasing a financial consolidations application that ensures the following consolidations concerns comply with SOX and other global compliance requirements:
Approvals and control: Critical to any compliant consolidations process is the ability to ensure that duties are distributed appropriately among enterprise personnel, and that they are well controlled. IT executives and CFOs should establish a formal workflow process to handle alerts and material variances, to ensure that there is a heightened visibility within the firm. A financial consolidations solution with integrated workflow capabilities and role-based BPM can provide this consistency. This is extremely critical to SOX Section 302, since these solutions provide confidence that financial reporting processes are controlled and that the information being reported is accurate.
Consistency of reporting: Ideally, firms should seek a single solution for planning, consolidations, and management reporting, to ensure a standard base of financial information for both internally- and externally-positioned reporting. The single application approach can prove extremely cost-effective, since it eliminates the need to manage multiple disparate applications, or attempt to integrate products that are difficult to merge. Doing so also helps ensure that the company is looking at a single version of the financial truth. A complete, consolidated financial picture is critical for any enterprise, and it is nearly impossible to achieve with an Excel-based process. A financial consolidations solution can ensure that the enterprise is aligned around a single view of consolidated financials.
Consolidations, planning and other BPM schedules: A BPM solution can monitor and manage the critical dates in the closing, planning, and reporting processes, and report on their progress toward deadlines.
Foreign exchange: A standard corporate approach to foreign exchange is critical for any global firm. During GL consolidations, a BPM solution can provide the necessary controls to ensure a consistent response to foreign exchange processes. For example, the rules and processes as well as standard conversion rates for various currencies that are employed in the organization can be controlled.
Import of data from a variety of ERP solutions: Larger enterprises typically operate on multiple instances of an ERP solution. In addition, often as a result of M&As, these companies tend to run several ERP applications from multiple vendors that tend to operate on different charts of accounts. CFOs must therefore consolidate financial results from multiple ERP solutions down to an appropriate detail level, to ensure visibility into accounting processes. A BPM financial consolidations solution can improve the consistency of this data by creating a standard, auditable approach to data import. It can also process this information according to the appropriate financial management processes. In the absence of this formal approach, firms struggle with error-prone approaches. Those companies using manually processes and Excel lack the necessary auditability and checks-and-balances, which increases the opportunity for fraud. In addition, sometimes adjustments may occur without the appropriate documentation and approvals, and these may be material enough to change the financial picture of the firm. IT executives should therefore collaborate with financial executives to select a formal BPM solution that can put more rigor into the financial consolidations process.
Inter-company transactions: Many larger firms have a high degree of line of business (LOB) integration. These inter-company transactions often require a major accounting effort. Consolidations software can help ensure that these entries meet enterprise standards, and are streamlined and auditable.
Journal entries: Many firms would prefer a journal entry-based approach to consolidating entries, including joint venture equity booking and eliminations, that meet requirements set forth by generally accepted accounting principles (GAAP). This approach ensures that balanced accounting entries are available to keep accounting records in order. Many times these entries will cross GLs, since they span different LOBs. IT executives at companies with multiple ERP systems supporting multiple business units should investigate a financial consolidations solution. A BPM application may be the best approach to ensure that entries are processed according to enterprise accounting standards and would meet auditor scrutiny.
Support for dynamic consolidations: Many firms have found that waiting for a monthly consolidation is not enough to ensure prudent financial management. They want to see the consolidations picture as it develops, and to set up compliance and reporting dashboards to understand the financial picture as it unfolds. Support for dynamic consolidations is critical for any automated solution that is to be considered.
An important side benefit of using a BPM application for consolidations is that it can link back to source data to provide drill-down support for the auditing process. Clearly, Excel cannot do this. Enterprise executives should provide visibility into transactions (or appropriate summarized details) that cause unexpected results. At the same time, they should link analyses to transactions and provide a more rapid response, rather than force users to drill back into various transactional systems. While it may not be appropriate to have the BPM solution sit on a large-scale enterprise data warehouse, many companies want to be able to drill through Web links back to source ERP and transactional applications.
As firms bring together the financial reporting and process management assertions required by SOX 404, they can benefit from connecting their BPM consolidations applications to governance tools. Such a connection helps them understand the status of the financial management assertions in the policies and procedures used to create those financial results. It is important to note that this does not only apply to SOX, but also many of the current global regulatory compliance requirements.
IT must understand this issue and help finance ensure that consolidations processes are optimized through the adoption of leading solutions for compliance. Depending on the degree of control required, the size of the organization, complexity of global requirements, and current BI and ERP platforms, certain solutions will be favored over others.
What to Look for in a BPM Solution for Sustainable Compliance
When a BPM solution is deployed with full leverage of built-in controls, workflow, audit trails, security, traceability, and other key compliance-enabling features, compliance initiatives will be greatly improved. To gain the full benefits of a BPM solution, executives should look for the following capabilities within a vendor product, and ultimately implement them:
Comprehensive "built-in" financial controls, which ensure that the end-state controls desired in performance management, financial reporting, and consolidations processes can be implemented.
Compliance metrics for global compliance management. Internal control compliance data is captured throughout the global enterprise, and then reported on (against?) overall compliance metrics (using The Committee of Sponsoring Organizations of the Treadway Commission (COSO)-based model or company-preferred framework).
Integration of financial results with financial process assessments. Financial data is integrated with corresponding compliance documentation and organized in a compliance and content management system, to help users make their closing and consolidation process more efficient. In addition, this reduces the risk of errors and misstatements and improves the completion of required compliance routines. For example, users, including internal and external auditors, can navigate through financial statements and automatically route to corresponding risks, controls, and test results that apply to any account).
Audibility. Audit ID, trace reports, and log files are provided to know, how, when, by whom, and by how much the system and data has been changed.
Role-based security, or the ability to set up multiple user groups (including external auditors) to provide "tailored" access to any area or data set included in the system.
Automated validation of reporting packages ensures completeness and accuracy of data submitted.
Drill-down capabilities from top level numbers to data source.
Data aggregation functionality. Automated data collection from disparate source systems and GLs.
Full transparency and traceability to all changes to financial data, whether done manually or by automated tasks, to track information from source to disclosure.
Automation of legacy/manual processes. Numerous manual activities from BPM processes (inter-company reconciliation, recurring journals, reports generation, data link to source systems, etc.) are automated to reduce BPM process cycle times dramatically.
Process monitory/disclosure speed, or the ability to monitor all processes as they occur. Management can focus on process blockages and optimizations.
Single integrated data model (IDM) enables one version of the truth.
Data categories. Multiple categories of data (budget, actual, forecast, SEC, GAAP, International Accounting Standards (IAS)) from a single data store, which reduces the need for vast reconciliations prior to disclosure.
Dimensions capable of providing required data to multiple stakeholder groups, and the ability to standardize chart-of-accounts in the system and unify all financial and management reporting.
eXtensible Business Reporting Language (XBRL) module discloses financial reporting in the emerging global standard that links accounting standards, compliance, and global reporting requirements.
Beyond Compliance
Improved compliance sustainability is clearly a major benefit of any firm that is seeking to target financial reporting and process improvement through a BPM implementation. Perhaps a more important opportunity for BPM is the ability to enable a performance management process, in many cases dismantling the web of Excel-based processes that do no enable a consistent approach to performance management, aligning IT and the business.
In addition to addressing compliance requirements, the major value of BPM will be realized in the following:
Consistent "one version of the truth" for financial and management reporting. This is incredibly important to provide a credible baseline for business planning and budgeting.
Alignment of metrics, dashboards, and reporting with planning data.
Facility to reorganize results into new organizational structures and model/predict performance when there are reorganizations, M&As, and divestitures.
Significant reduction in the rampant use of spreadsheet and offline processes in the results and budgeting processes. Offline processes create havoc for most organizations when attempting to produce a unified presentation of results.
A single interface to provide enterprise collaboration for financial process management that can provide auditable approvals and workflow with the appropriate alerts and notifications. BPM can provide actionable information where and when required within the enterprise.
Reduced costs with improved accuracy around enterprise financial processes.
Summary
BPM technologies can provide an effective solution to the financial reporting and control dimensions for regulatory compliance. Specifically, these tools offer an auditable and controlled environment for many firms that are still dealing with legacy systems, offline spreadsheets, and loosely-integrated applications. Microsoft Excel is still the leading solution in firms for financial consolidations. Unfortunately, Excel cannot even begin to provide the necessary control for most of the recent regulatory initiatives without a significant series of manual checks and balances.
RFG believes BPM can provide an important capability to sustain compliance and provide the requisite enterprise alignment for results management. However, once a firm's regulatory approach has been improved, the real opportunity with BPM will be one that creates a more competitive firm through better performance management of enterprise and operational processes.

