While the Commission report - published yesterday - made passing reference to the deployment of 'patchy and outdated' technology infrastructure in the UK banking sector, Intellect believes it missed a trick in failing to address this fundamental problem as part of its recommendations.

Ben Wilson, associate director for financial services programmes at Intellect comments: "Many of these issues around conduct, competition and supervision have a common denominator - the technology infrastructures that facilitate all the operations of 'the bank'. You reduce the complexity of this, and you ultimately make life a lot easier for the banks and the regulators, and you improve the ability of the banks to serve the customers and the wider economy."

Intellect is calling on the Government to take on board this issue of technology infrastructure alongside the recommendations within the Commission's report, and in particular:

• Consideration of a greater number of technology-literate individuals in decision-making positions on boards
• Encouraging banks to more comprehensively map their existing systems and processes - which should have been done as part of ongoing recovery and resolution requirements. If this is undertaken, change can be implemented more quickly and with reduced cost; weaknesses and risks can be better identified before they impact customers; and decisions on issues such as branch divestures can be made with greater certainty
• Clarification from regulatory authorities on what they want banks to be able to do in the future and allow banks to work towards this, without wasting money on duplicative regulatory implementation
• Facilitating a greater degree of collaboration across banks, to identify how common problems of technology infrastructure - outlined comprehensively in the Commission's paper - can be addressed more systematically and effectively

Says Wilson: "The public has only recently gained an insight into the all encompassing nature of the technology that underpins their banks, and indeed the entire financial system, through a demonstration of what happens when this stops working. A light has been shone on the 90% of the technology iceberg that is underwater."

Many of the issues highlighted in the paper are the product of a technology estate across individual banks that is simply too complex, he says, and does now not allow the banks to adequately "know their own operations, their customers or implement change on a timely and cost effective basis".