"Organisations have cultures and individuals have competence. When we are ill we don’t really care about the culture of the NHS but the competence of the doctor.
"We assume they have had a suitable education and training and are capable of making accurate diagnoses and recommending the very best treatments.
"The Financial Services Authority has now published the final Mortgage Market Review which is intended to put right all that was wrong within the mortgage industry by imposing a product and process blueprint on organisations active in the mortgage market.
"Where is the individual in this?
"Well the FSA has decided to put back individual registration of brokers. The focus is on organisations. John Cupis at Sesame, Stephen Smith at Legal & General and Paul Shearman at Openwork all believe that individual records are important. I do too.
"The banking industry has hit a nadir following the credit crunch, self-cert lending, PPI mis-selling, incentives driven sales and the LIBOR scandal.
"One might argue that this is a result of dysfunctional cultures within the organisations involved but I think that these problems originate with the competence of the individuals in charge.
"My point is this. In the final analysis we rely on the competence of professionals. If the industry wants to put its house in order, it must begin with the individual.
"No amount of product and process tinkering will deliver the cultural changes required.
"Back in 1991 I designed the UK’s first instant mortgage offer system for Sun Alliance Mortgages many years before GMAC and BM Solutions and I went on to design similar systems for many other lenders.
"My objective was to improve service quality and free individuals from routine, repetitive tasks and allow them to concentrate on issues of judgment where they could bring their professional competence to bear.
"But ultimately technology like this was used to strip people out of the process entirely.
"Competence went out of the window and the credit crunch became almost inevitable as we relied on computer systems rather than experience and judgment. Big mistake!
"Then in 2001 I designed and implemented the systems at the Mortgage Code Compliance Board, the non-statutory mortgage regulator prior to the FSA taking over.
"This time my brief was to build in just a few months a system for lender and broker registration and renewal which also would support call centre, correspondence and compliance functions.
"The project was a success. The system contained records for 38,147 mortgage sales staff at an individual level including personal training and competence and fitness and propriety data.
"But when the FSA took over this brand new system, based on a powerful Seibel platform, was summarily junked together with all its data. Big mistake!
"The number of brokers has now fallen to fewer than 10,000 so managing individual data is a less onerous challenge.
"But while the FSA has pondered MMR for four years it has failed to deliver a suitable system.
"I suspect we will come to realise that this focus predominantly on the organisation represents an opportunity missed."