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The reporting change that kept growing: a regulatory reporting project

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The reporting change that kept growing: a regulatory reporting project

Arclight Bank is delivering a new regulatory report. The report specification is baselined at version 2.1. Three weeks before the stage boundary, the regulator's liaison asks for 18 additional data fields. The project manager's initial assessment, based on a two-hour workshop, is three days and £8k. A fuller impact analysis shows changes to the data warehouse, four interfaces, the reconciliation process, and the acceptance criteria; the estimate rises to £95k and six weeks. The change budget is £80k, and the project board has delegated change authority to the project manager up to £25k. The senior user wants the fields included in the current stage. Six other changes are open, two of which affect the same interfaces. The stage tolerance is two weeks and £40k.

1. How should the project manager process the request for the 18 additional data fields?

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The request must go through the change control procedure, regardless of who asked for it. The project manager should record it in the issue register, complete a proper impact analysis, and then decide who has authority to approve it.

The initial three-day, £8k estimate is not credible against the fuller analysis of £95k and six weeks. The project manager should use the fuller analysis, covering the data warehouse, four interfaces, reconciliation, acceptance criteria and the effect on the stage boundary. The request exceeds the project manager's delegated authority of £25k and would take the stage beyond its two-week and £40k tolerances. It therefore cannot be approved by the project manager alone; it must go to the project board with options: approve, reject, defer to a later stage, or approve part of the request.

The change budget of £80k is relevant but not sufficient on its own, because the change also breaches stage tolerances. The project manager should show the cumulative effect with the other open changes, particularly those affecting the same interfaces, and recommend a decision. If the board approves, the report specification baseline, PID, stage plan and acceptance criteria must be updated, and configuration management must reflect the new version.

2. What should the project manager do about the two other open changes affecting the same interfaces?

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Changes cannot be assessed safely one at a time when they touch the same configuration items. The project manager should bring the two other open changes into the same impact analysis, because their combined effect on the interfaces, data warehouse and reconciliation may be greater than the sum of the individual estimates.

The project manager should check the configuration item records and status accounting for the interfaces, confirm which versions are baselined, and identify any overlap or conflict between the changes. If the changes compete for the same resources or the same interface release, the board should prioritise them rather than approving each in isolation. The cumulative draw on the £80k change budget should also be shown, because approving all three could exhaust it and still leave other work unfunded.

A practical recommendation is to group the changes into a single decision paper with options: implement together, sequence them, defer one or more, or reject those that do not justify their cost. The project manager should update the issue register and configuration records so that the board's decision is traceable and the baselines are changed only once.

3. The regulator's liaison says the fields are mandatory. Does that change the change-control process?

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It changes the priority and the consequences, but not the process. A mandatory regulatory requirement is a strong reason to approve a change, but it still needs impact analysis, authorisation and configuration control. Bypassing change control would leave the project with an uncontrolled baseline and no clear record of who accepted the cost, time and quality impact.

The project manager should confirm the requirement in writing, assess what 'mandatory' means in practice, and include it in the change assessment. The board may decide that compliance risk outweighs the cost and delay, but it should do so explicitly. If the change takes the stage beyond tolerance, an exception report is required. The business case should be checked: £95k and six weeks may affect the regulatory deadline and benefits, and the board needs to see that. If approval is given, the report specification, stage plan, acceptance criteria and any affected product descriptions must be re-baselined, and the regulator's requirement should be traced in the configuration records.