Most banking controls look straightforward when viewed one account at a time. A payment has an approval process. An account has authorised users. A team knows who should have access. A transaction can be checked and, if necessary, investigated later.
The difficulty starts when those same disciplines have to be maintained across hundreds or thousands of accounts, multiple banking partners, different jurisdictions and several internal teams.
Scale does not suddenly make an individual control less sensible. It makes consistent execution harder.
For credit servicers and loan administration businesses, that distinction matters because banking operations often sit inside a wider responsibility for client assets and cashflows. The question is not simply whether the right controls exist, but whether they can still be applied, monitored and evidenced reliably as the operating environment becomes more complex.
Jeremy Slade is Head of Digital Solutions, Private Markets. He has more than 25 years of experience in financial services and has built and led businesses and commercial teams across Europe, Asia, the Middle East and the US. Having worked extensively with private markets and institutional investors, Jeremy brings a global perspective on how technology, banking and financial infrastructure are evolving.
Consider the difference between managing 20 bank accounts and managing 2,000.
With 20, experienced employees may know the relevant banks, users and processes almost by memory. Access changes are relatively visible. Exceptions are easier to spot. If somebody needs to investigate a payment, there are only so many places to look.
At 2,000 accounts, the underlying control questions are largely the same, but the number of times the organisation has to answer them has multiplied.
Who should have access to this account? Which team is responsible for it? What approval process applies to the payment? Which banking environment contains the information? How quickly can the organisation establish what happened if somebody needs evidence later?
None of those questions is particularly exotic. The difficulty is answering them consistently across a large and constantly changing banking estate.
That is where a control environment can start to become operationally expensive even when the underlying policies remain sound.
At smaller scale, organisations can often compensate for fragmented processes through experienced people and informal knowledge.
One team knows that a certain bank works differently. Another knows where a particular report is stored. Someone else remembers which process applies to a particular account.
That can work surprisingly well. Until it has to scale.
As the number of accounts, banks and teams grows, the organisation becomes more dependent on people knowing the exceptions. The control may still exist, but operating it becomes more complicated. Proving afterwards that it was followed can become more laborious too.
A control is not valuable only because it has been designed correctly. It also needs to be practical enough to operate repeatedly and consistently across the organisation.
That is where banking infrastructure starts to matter.
Mount Street illustrates the size of the challenge. Within its servicing operations, the business manages several thousand bank accounts across dozens of banking partners globally and processes approximately 35,000 payments each year. As the firm continued to grow internationally and take on more complex mandates, it wanted a banking operating model that could scale while maintaining strong controls and governance.
That is a different problem from simply adding another approval step. At that scale, governance is partly about creating enough consistency around the banking environment that controls remain manageable as the organisation grows.
Mount Street says that since going live with Cobase it has seen improvements in efficiency, visibility and control, while establishing a more consistent operating model across regions. Teams also have easier access to banking information and payment processing has become more streamlined.
The important point is not that complexity has disappeared. It has not. The business still operates across thousands of accounts and numerous banks. What changes is the environment in which those relationships are managed.
Servicing businesses should not aim to make every structure identical.
Different clients have different requirements. Different accounts can serve different purposes. Different jurisdictions and banking relationships can require different processes.
Some variation is legitimate and unavoidable. The problem is unnecessary variation.
If every banking relationship creates a slightly different internal process, employees have to spend more effort distinguishing between what is genuinely required by the underlying structure and what is simply the result of fragmented operations.
A more consistent framework makes that distinction easier. The organisation can establish a clearer normal way of working while still allowing for legitimate exceptions.
If everything is an exception, eventually nothing really looks exceptional.
There is another dimension to scale that is easy to underestimate: evidence.
A control may have operated correctly, but can the organisation demonstrate that efficiently when it needs to?
In a fragmented banking environment, reconstructing what happened can mean consulting different portals, systems or teams. The work required to produce evidence may be far greater than the original transaction itself.
That matters operationally because governance is not only about preventing mistakes. It is also about being able to establish what happened, who was involved and which information was available when questions arise.
For businesses acting on behalf of clients, that level of transparency becomes increasingly important as the banking estate grows. The more accounts and banking relationships the organisation manages, the less sustainable it becomes to rely on individuals knowing where the evidence can be found.
When a servicing business grows, it does not necessarily need radically different controls. Payment approval, access management and oversight remain familiar disciplines.
What changes is the organisation's ability to administer them.
A process that works because five experienced people know exactly what to do may struggle when the business spans several teams, regions and thousands of accounts. A control that can be checked manually across a small estate may become disproportionately burdensome when the account population multiplies.
The challenge therefore shifts from having controls to making those controls operationally controllable at scale.
Technology does not replace responsibility, judgement or governance. But the structure of the banking environment can make the difference between controls that remain practical as the business grows and controls that become increasingly dependent on manual coordination.
For a servicing business, that distinction can determine whether growth strengthens the operating model or gradually makes it harder to govern.
Cobase can help servicing businesses manage multiple banks, accounts and payment processes through a more centralised banking environment, supporting more consistent access to information, payment workflows and operational oversight across the organisation.
For firms managing banking activity across large numbers of separate client structures, that can make existing governance processes easier to operate at scale without removing the need for local responsibility, internal controls or professional judgement.