CAITLIN TAYLOR Caitlin Taylor LinkedIn ↗
Agile Controls, by Design

The planted leg.

Structure does not slow a programme down. It is the thing that lets it turn.

By Caitlin Taylor · adapted from my white paper

When a regulator issues a Section 166 Requirement Notice, two programmes begin. The visible one belongs to the skilled person: scoped by the regulator, counted in published statistics, fee averaging close to a million pounds. The invisible one belongs to the firm: RFI management, document production, interviews, evidence packs, remediation planning, governance, reporting, and the handover into business as usual.

Nobody publishes what that second programme costs. For a multi-business-unit bank it routinely exceeds the skilled person’s fee. And unlike the fee, it is a cost the firm can actually control.

£992k AVERAGE SKILLED PERSON FEE THE PUBLISHED NUMBER · ABOVE THE LINE THE WATERLINE — WHAT THE MARKET SEES 1.5–3× THE FIRM-SIDE RESPONSE PROGRAMME · VS THE FEE UNPUBLISHED · PRACTITIONER ESTIMATE The number the firm controls is the one nobody measures.
Fig 1. The cost iceberg

Why these programmes fail so predictably

A Section 166 response is not a large but ordinary change programme, and three properties explain why treating it like one never quite works.

THE BANK THE SKILLED PERSON THE REGULATOR runs delivery consumes evidence consumes progress ONE GOLDEN SOURCE ONE DATASET · EVERY AUDIENCE Consistency across the three is the programme’s real currency.
Fig 2. Three masters, one dataset

Two beliefs that feel prudent and are backwards

When the Notice lands, the clock is already running, and almost every firm makes the same call on the same logic.

Belief one: structure takes too long to build. So trackers, reporting and processes get assembled mid-flight and iterated under fire, while delivery is already underway. Belief two: too much governance makes a programme rigid. So governance is kept light, and then stripped further whenever things get tight.

Both beliefs are understandable. Both produce the same six failures.

BELIEF ONE “Structure takes too long to build” BELIEF TWO “Governance makes us rigid” 01 Disconnected tooling — spreadsheets that don’t speak to each other 02 Governance retrofitted rather than designed 03 The silent slippage engine — a moved date nobody sees until it detonates 04 Reconciliation as a way of life — three audiences, three versions 05 The handover cliff — response to remediation, unstructured 06 The false agility spiral — strip governance to go faster, go slower
Fig 3. Two beliefs, six failures

Agility comes from firm controls

A ballerina doesn’t pivot on the leg that moves. She pivots on the leg that holds: strong, controlled, planted.

This is the whole argument. Prepared comms, briefed stakeholders, locked change windows and one golden source are not what stop a programme pivoting. They are the planted leg that makes the pivot possible. When the skilled person’s focus shifts or new findings land, a change made once flows through plan, reporting and comms; the programme absorbs it in days instead of firefighting for weeks.

ACON stands for Agile Controls, and the name is the method.

Where it came from

Early in a major UK bank’s Section 166, as design lead, I put forward an operating model along these lines: governance, sprint cycles, a controlled delivery workflow, maintained SOPs. With the clock already running it felt, understandably, like too much structure too soon, and the programme pressed on.

Two years of building-while-delivering followed. Trackers, reports and SOPs reworked over and over, strategy reset after reset, until the programme itself asked for a proper workflow. Once the structured model was adopted, validation rates rose by more than 50%, every phase submission passed skilled person review first time, and submissions went to the regulator on time.

ACON was built during that time. The steps of a Section 166 are substantially the same every time; only the scope, the business units and the findings change. So the foundation can be built once, properly, in advance, then moulded to each bank in weeks rather than assembled under fire.

50%+
uplift in validation rates once the structured model was adopted
3 / 3
phase submissions passed skilled person review first time
2–3 wks
mobilisation, against a two-year build-while-delivering cycle

The system

Mobilise once, then deliver and govern in parallel: the inverse of building while delivering.

MOBILISATION weeks 1–3 · builds the foundation, once DELIVERY week 4 → close · executes from the plan PMO two-week sprints, alongside STAGE ONE · RESPONSE STAGE TWO · REMEDIATION Scoping &Mobilisation Info Gathering& Fieldwork Reporting &Remediation Plan Handover &Mobilisation RemediationDelivery BAU Integration& Close ▸▸▸ ▸▸ Every phase ends at a hard gate — no sign-off, no progress. The programme closes on signed business-unit acceptance.
Fig 4. Two stages, six gates

One source, six views

The suite serves every audience from one dataset. A master programme workbook feeds SLA-timed workflow trackers for the volume work of a review (RFIs, interviews, case builds, sample testing, findings checks, report responses), with one refresh updating every report.

The case handler sees a simple queue. The programme director sees six phases. Internal audit sees everything, read-only. Microsoft-native and macro-free throughout: Excel, SharePoint and PowerPoint, the estate the bank already licenses, trusts and audits, plugging into Power BI, Tableau, the GRC platform and MS Project where needed. No new platform, no procurement cycle, no data leaving the estate.

MASTER WORKBOOK ONE GOLDEN SOURCE CASE HANDLER PROGRAMME DIRECTOR THE BOARD SKILLED PERSON THE REGULATOR INTERNAL AUDIT a simple queue six phases one page indexed evidence progress MI everything, read-only Microsoft-native and macro-free — the estate the bank already licenses, trusts and audits.
Fig 5. One source, six views

What it comes down to

On a response programme running at half a million pounds a month, a “normal” 30% overrun is roughly seven additional months: extended run-rate, extended skilled person engagement, and a conversation with the regulator nobody wanted. Weak governance is consistently cited among the leading root causes.

The time invested at mobilisation is the cheapest time in the whole programme. Re-do work and firefighting are the price of skipping it.

A note on what this paper does not contain

The engineering of the toolkit itself stays out of the public edition. What is here, the diagnosis and what good looks like, is deliberately generous. Expertise is demonstrated, not asserted.