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Automation in Financial Services 91.4 Emerging Trends and Issues 1625

91.4 Emerging Trends and Issues

There are a number of trends and issues affecting small

banks and credit unions. The US Federal Government

continues to impose additional regulations related to

tracking customers and customer activity. Customers

continue to shift their payments to electronic forms.

New technologies and channels, such as Web 2.0 appli-

cations, continue to emerge, and automation to support

these trends is leading to banks and credit unions using

more vendors, with the accompanying issues involved

in integrating these systems.

91.4.1 Role of Integration

Implementing new products requires new systems.

Implementing new channels requires new systems. Im-

plementing new processes requires automation. Most

community banks and credit unions do not have the

skills to automate this on their own. They are either out-

sourcing their processing to ASPs and other vendors,

or they rely on packaged software. To automate a new

product, channel or process requires identifying the ap-

propriate provider and then implementing the system

and integrating it with the existing systems.

The integration required for basic functionality is

addressed by the vendor; for example, to implement In-

ternet banking requires integrating the Internet banking

software with the bank or credit union’s core processing

system, and that provided by the vendor. When the inte-

gration is not central tothe automationproject, however,

it is frequently omitted by the vendor and not examined

(at least initially) by the bank or credit union.

Where this has been particularly problematic is with

basic customer information. When a customer changes

their email address in one channel, they expect that it

be changed everywhere in the banks systems. Because

of the numerous systems and vendors, this frequently

is not done. Even when the bank or credit union uses

a single vendor (e.g., FISERV) their products may not

be completely integrated, because they have frequently

purchased the software from another vendor (or pur-

chased the vendor to acquire the software).

This type of integration becomes a vendor manage-

ment issue more than a technical issue. The integration

issues need to be part of the software/vendor selection

and contracting process. Service level agreements cen-

tered around integration are difﬁcult, since the future

systems are not identiﬁed. User group pressure, how-

ever, appears to be effective in getting the vendors to

focus on this issue. This implies that, when selecting

a vendor, banks and credit unions need to choose those

large enough to have an effective user community.

91.4.2 Regulation

The US Federal Government is increasingly regulating

ﬁnancial institutions’ operations. The USA Patriot Act,

the fair and accurate credit transactions (FACT) act plus

additional rules by the Securities and Exchange Comis-

sion (SEC), Financial Accounting Standards Board

(FASB), and others add to the regulatory burden. New

laws, such as H.R. 3012, The Fair Mortgage Practices

Act of 2007, are introduced and existing regulations

change each year. These regulations are disproportion-

ately burdensome for small ﬁnancial institutions, and

some believe that they will drive small banks out of

business [91.30].

Automation projects to fulﬁll regulatory require-

ments are difﬁcult, because they usually have a ﬁxed

deadline for implementation, which can be unrealistic.

These automation projects will not provide a competi-

tive advantage. They will not support strategic efforts.

They will not reduce costs (except through penalty

avoidance). Typically, the goal is to get them in as

cheaply as possible. The risk is that this will lead to

higher costs long-run as the capabilities need to be in-

tegrated throughout other systems. This is particularly

true for regulations requiring monitoring suspicious ac-

tivity, where the bank needs to identify and analyze

a picture of a customer’s entire relationship with a bank.

91.4.3 Shift From Paper

to Electronic Payments

The number of paper checks and the value of those

checks are ﬁnally decreasing as consumers and busi-

nesses shift to electronic payments. The back-end

settlement infrastructure is largely automated, but new

front-end technologies – new payment channels – con-

tinue to emerge. Using mobile phones for payments has

been available in Japan for a number of years, but is in

its early stages of adoption in the USA. Small banks and

credit unions again face a decision of whether they want

to offer their customers and members a new channel.

The shift to electronic payments, however, is

bypassing person-to-person payments. PayPal allows

person-to-person payments, but has not had a signiﬁ-

cant effect on the number of paper-based transactions.

Mobile technologies offer the possibility of allowing

Part I 91.4

1626 Part I Home, Ofﬁce, and Enterprise Automation

individuals to make and receive payments. Citigroup

offersthis service through Obopay, andis currently pay-

ing its customers to sign up for the service. Obopay is

similar to a prepaid credit card, but both parties must

use the service.

91.4.4 Emerging Technologies – Web 2.0

Web 2.0 technologies for social networking appear, at

ﬁrst glance, better suited for enhancing internal bank

and credit union operations. Communities of loan of-

ﬁcers, compliance personnel or packaged systems users

would help each group more efﬁciently and effectively

carry out their duties. They would provide a place to get

help, gain insights, and kvetch. They could either be op-

erated by the bank or by independent third parties and

would not need to integrate with existing system.

Banks, however, are exploring the use of social

networking as a front-end to customer education and

interaction. Wells Fargo is leading the way, and if it suc-

cessful, it will pressure small banks and credit unions

to follow suit. Wells Fargo initially created a site on

Second Life. The site provided both games and ﬁnan-

cial education. To gain more control over the customer

experience, they left Second Life and started their own

virtual world, Stage Coach Island.

On Stage Coach Island, participants can network

with each other and do activities together, such as mo-

torbike racing and parachuting. They can learn about

ﬁnancial products and services, ostensibly to develop

ﬁnancial responsibility. Although there is little Wells

Fargo advertising, it has the potential to provide Wells

Fargo with a wealth of information about their cus-

tomers or potential customers.

At the moment, small banks and credit unions most

likely do not have the skill set toduplicate Wells Fargo’s

efforts. Although there is vendor-supplied software for

developing virtual worlds, there are not vendor-supplied

virtual worlds available for banks and credit unions to

brand and customize for their customers and members.

91.5 Conclusions

Small banks and credit unions face unique consider-

ations when automating. They have to keep up with

larger institutions, but do not have the resources to ex-

ecute these projects on their own. This causes them

to rely on external vendors, which raises integra-

tion issues, especially for customer-facing systems.

A changing business environment and new technolo-

gies require that small banks and credit unions continue

to invest in automation, but to be successful they

will need to ensure that these projects support their

strategy and that the approach is appropriate for this

strategy.

References

91.1 S. Ang, D. Straub: Production and transaction

economies and IS outsourcing: A study of the

US Banking Industry, MIS Quarterly 22(4), 535–552

(1998)

91.2 Fortune 500 (2006)

http://money.cnn.com/magazines/fortune/

fortune500/snapshots/309.html, viewed 12/20/2007

91.3 Wanda Michalenko Memorial Federal Credit Union

website

http://creditunionaccess.com/cu20418.htm,viewed

12/22/2007

91.4 NAICS Association: 52 Finance Industry (2007)

http://www.naics.com/censusﬁles/

NDEF52.HTM#N52 viewed 12/20/2007

91.5 MyTerm: The Revolutionary Online Life Insurance

for Bank Customers (2007), http://www.prudential.

com/view/page/14252?seg=10&name=bank-

channellaunchednewlifeproduct, viewed 1/5/08

91.6 T. Steiner, D. Teixeira: Technology in Banking: Cre-

ating Value and Destroying Proﬁts (Business One

Irwin, Homewood 1990)

91.7 K. Flinders: The evolution of stock market tech-

nology, ComputerWeekly.com, November (2007),

http://www.computerweekly.com/Articles/2007/11/

02/227883/the-evolution-of-stock-market-

technology.htm, viewed 12/20/2007

91.8 R. Cole: Dow falls 23.27 in heavy program trading,

New York Times, July 11 (1990)

91.9 A. Khanna: Program Trading, EGO (2006),

http://www.egothemag.com/archives/2006/01/

program_trading.htm, viewed 1/22/2007

91.10 Credit Union Philosphy, Credit Union National As-

sociation (2009) http://www.creditunion.coop/

history/cu_philosophy.html, viewed 2/10/2009

91.11 Federal Financial Institutions Examination Council

IT Examination Handbook: Retail Payment Systems,

Part I 91

Automation in Financial Services References 1627

March (2004), http://www.fﬁec.gov/fﬁecinfobase/

booklets/operations/23.html

91.12 A. Bharadwaj: A resource-based perspective on

information technology capability and ﬁrm perfor-

mance: An empirical investigation, MIS Quarterly

24(1), 169–196 (2000)

91.13 M. Wade, J. Hulland: Review: The resource-based

view and information systems research: Review,

extension, and suggestions for future research, MIS

Quarterly 28(1), 107–142 (2004)

91.14 C. Parton, J. Glaser: Myths about IT spending,

Healthcare Inform. 19(7), 39–40 (2002)

91.15 A. Vrechopoulos, G. Siomkos: The adoption of in-

ternet shopping by electronic retail consumers

in Greece: Some preliminary ﬁndings, J. Internet

Bank. Commer. 5(2), 1–3 (2000)

91.16 J. Ross, P. Weill: Six IT decisions your IT people

shouldn’t make, Harvard Bus. Rev. 80(11), 89–92

(2002)

91.17 D. Hancock: The ﬁnancial ﬁrm: Production with

monetary and nonmonetary goods, J. Polit. Econ.

93(5), 859–880 (1985)

91.18 R. Hirschheim, M. Lacity: The myths and realities of

information technology insourcing, Commun. ACM

42(2), 99–107 (2000)

91.19 R. Hirschheim, R. Sabherwal: Detours in the path

toward strategic information system alignment,

Calif. Manag. Rev. 44(1), 87–108 (2001)

91.20 M. Lacity: Lessons in global information tech-

nology sourcing, IEEE Computer 35(8), 26–33

(2002)

91.21 M. Lacity, L. Willcocks: IT sourcing reﬂections:

Lessons for customers and suppliers, Wirtschaftsin-

formatik 45(2), 115–125 (2003)

91.22 N. Melville, K. Kraemer, V. Gurbaxani: Review:

Information technology and organizational perfor-

mance: An integrative model of IT business value,

MIS Quarterly 28(2), 283–322 (2004)

91.23 T. Espino-Rodriguez, V. Padron-Robaina: A review

of outsourcing from the resource-based view of the

ﬁrm, Int. J. Manag. Rev. 8(1), 49–70 (2006)

91.24 W. Richmond, R. Carton: Does IT Sourcing Mat-

ter: Empirical Evidence from Credit Unions, Working

Paper, Western Carolina University, Cullowhee, NC

28734, (2007)

91.25 Retail Banking Research, Ltd.: Banking in the on-

line World, White Paper (1996)

91.26 Dynamicnet: Transforming Consumer Banking

Through Internet Technology, White Paper (2001)

91.27 N. Olazabal: Banking, the IT paradox, McKinsey Q.

1,17–51(2003)

91.28 K. Hoffmann: Online banking aligns practices,

Banking Technology News, March (2003)

91.29 L.M. Hitt, F.X. Frei: Do better customers utilize

electronic distribution channels? The case of PC

banking, Manag. Sci. 48(6), 732–748 (2002)

91.30 United States Senate: Testimony of Bradley E.

Rock On Behalf of the American Bankers As-

sociation Before the Committee on Banking,

Housing and Urban Affairs, June 22, 2004,

http://banking.senate.gov/_ﬁles/rock.pdf,viewed

1/5/08

Part I 91

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1629

e-Governmen

92. e-Government

Dieter Rombach, Petra Steffens

e-Government in its most generic form refers to the

automation of government processes and services

by using modern information and communication

technologies, usually – but not necessarily – in

combination with web technology. The transition

from paper-based administrative workﬂows to

electronically supported process chains involving

a multitude of stakeholders (in particular, gov-

ernment agencies, citizens or companies) is a key

driver of today’s e-Government policies. Whereas

in their early manifestations, e-Government ef-

forts were primarily geared towards improving

internal administrative performance, today’s focus

is on increasing the overall quality of government

services. The aim is to improve the living condi-

tions of citizens and to create a favorable climate

for business.

This chapter provides a short introduction to

the basic concepts of e-Government, explains how

e-Government evolved over the last 10 years,

92.1 Automating Administrative Processes .....1629

92.2 The Evolution of e-Government .............1630

92.3 Proceeding from Strategy to Roll-Out:

Four Dimensions of Action.....................1633

92.3.1 Strategy .....................................1634

92.3.2 Processes and Organization ..........1637

92.3.3 Technology .................................1637

92.3.4 Project and Change Management ..1638

92.4 Future Challenges

in e-Government Automation................1639

92.4.1 Political Challenges .....................1640

92.4.2 Engineering Challenges................1640

References ..................................................1641

gives an overview of the dimensions on which

the design and implementation of successful

and sustainable e-Government services has to

proceed, and outlines some future challenges for

e-Government.

92.1 Automating Administrative Processes

The 20th century has been the era of digital revolu-

tion. Information and communication technology (ICT)

has deeply affected business processes, service provi-

sioning, production, as well as the private habits and

activities of the citizens in our modern societies. In fact,

ICT has become an integral part of most of today’s

products and services.

ICT has also had a signiﬁcant impact on the way

in which government agencies perform their tasks. The

standard inventory of government automation today

comprises email, interactive websites, downloadable

forms, and sometimes information upload. However,

for most governments the level of automation and

integration is lagging behind the computerization of

businesses. This can be observed in all kinds of gov-

ernment activities and services: internal workﬂows

as well as processes between government and its

external partners (citizens and business). Today’s chal-

lenge for government agencies all over the world is

to reach a seamless integration of their own work

processes with those of their internal and exter-

nal partners. This concerns the following types of

collaboration:

•

Government-to-government (G2G): interactions in-

side or between government agencies

•

Government-to-citizen (G2C): services that govern-

ment delivers to its citizens

•

Government-to-business (G2B): workﬂows be-

tween government and business.

Part I 92

1630 Part I Home, Ofﬁce, and Enterprise Automation

Many modern governments have understood that

through the use of electronic media they can increase

the efﬁciency, quality, and transparency of their services

and thus increase the attractiveness of their national

economy in a globalized world. Solutions developed

to this end are summarized under the umbrella of

e-Government.

This chapter describes how e-Government evolved

over the last 10years, provides an overview of the

dimensions which need to be addressed in the de-

sign and implementation of successful and sustainable

e-Government services, and outlines some current chal-

lenges for e-Government.

92.2 The Evolution of e-Government

The beginnings of e-Government were in the late 1990s

when ICT, especially the use of online media, was rec-

ognized as an important means to improve theefﬁciency

and quality of government services. The use of ICT

was often inspired by achievements made in e-Business,

which demonstrated that doing business online could

help increase the efﬁciency of business processes in

a company as well as between companies.

Since 1995, Gartner has used the concept of hype

cycle to describe the relative maturity of technologies,

IT methodologies, and management disciplines. Hype

cycles distinguish ﬁve phases [92.2]:

e-Government at its peak

Development of master plans

Rankings note that administration

is trailing behind

Budgets get slashed

Disillusionment in the IT industry and in

consulting companies

E-government failures

become known

Benefit- and industry-driven

e-Government

Integration of e-Government

and e-Business

Political disillusionment

Online services offered by administration

Customer-oriented e-Government

Invention of e-Government

End of e-Business hype

Expansion of government data networks

ICT as an element of

modernizing administation

Till 2000 2000 2001/2002 2004 2006 2008 2010

Visibility

Maturity

Integration of

e-Government and

e-Business

Slope of

enlightenment

Trough of

disillusionment

Peak of inflated

expectations

e-GovernmentTechnology

trigger

Fig. 92.1 Evolution of e-Government example. Note: The dotted line shows the development line of e-Business

(after [92.1])

1. Technology trigger: The ﬁrst phase of a hype cy-

cle, which is provoked, e.g., by a product launch

or other event that generates signiﬁcant press and

public interest

2. Peak of inﬂated expectations: The second phase,

which is characterized by overenthusiasm and un-

realistic expectations

3. Trough of disillusionment: Technologies fail to

meet expectations and quickly become unfashion-

able

4. Slope of enlightenment: Despite a decrease in public

and press interest, some businesses keep up their in-

Part I 92.2

e-Government 92.2 The Evolution of e-Government 1631

terest and experiment to understand the beneﬁts and

practical application of the technology

5. Plateau of productivity: The technology becomes

increasingly stable; its beneﬁts become widely

demonstrated and accepted.

Adapting Gartner’s hype curve to the evolution of

e-Government in Germany, Büllesbach has drawn an

exemplary development line of e-Government [92.1], as

can be observed in analogous forms in many econom-

ically developed countries (Fig. 92.1). Throughout the

1990s, ICT was mainly regarded as a means of mod-

ernizing administration by facilitating communication

and workﬂows between state agencies. For Europe, this

is illustrated by the e-Government country fact sheets,

which the European Union publishes yearly for 33 Eu-

ropean countries [92.3].As a consequenceof supporting

internal work processes with ICT, new government data

networks were established and the coverage and capac-

ity of existing ones were increased.

By the beginning of the millennium, the concept of

e-Government made its debut, implying a shift in fo-

cus: Turning away from the primarily internal use of

ICT, governments started to perceive beneﬁts in apply-

ing new technologies to offer electronic services to their

clients (e.g., electronic voting machines (Fig. 92.2)).

Early applications developed at that time mainly fo-

cused on citizens and were usually limited to providing

access to information, allowing simple forms of inter-

action such as exchanging e-Mails or using feedback

forms. e-Government projects at the time were often

conducted separately from each other, leading to iso-

lated and incompatible solutions.

To overcome this situation, governments started to

realize the need for a more systematic approach: e-

Government master plans were thus developed that

put existing and planned projects under the um-

brella of a common strategy. With the development

of master plans that gave rise to high expectations,

e-Government also became more visible on the polit-

ical agenda and reached its hype peak. Expectations

were dampened though, when it became clear that of-

ten e-Government lead times were incompatible with

politicians’ striving for timely success and that under-

estimation of a task’s complexity and of the challenges

posed by its political context (e.g., federal structures

with complex decision processes), not only let projects

overrun time and budget but also failed to evoke

acceptance [92.4]. A prominent case in point is the Ger-

man FISCUS (Föderales Integriertes Standardisiertes

Computer-Unterstütztes Steuersystem – federal inte-

a) b)

Fig. 92.2a,b Examples of electronic voting machines from around

the world:

(a) Inﬁnity voting terminal (courtesy of Microvote

General Corporation),

(b) MV-464 voting station (courtesy of Mi-

crovote General Corporation)

grated standardized computer-supported tax system)

project, which aimed at developing uniform tax soft-

ware for the ﬁscal administration in Germany, but was

stopped and entirely reoriented after 13years without

producing the expected results [92.5]. As a conse-

quence, e-Government budgets were cut and failures of

e-Government projects became public. In addition, it

was recognized that citizens, who had so far been the

primary target of e-Government efforts, did not access

e-Government services at a sufﬁcient rate to realize the

expected return on investment.

This political disillusionment was overcome mainly

by two shifts in focus: ﬁrst, technology as a major

driving force for developing new solutions was re-

placed by the goal of creating customer beneﬁt; second,

companies, which have more frequent and regular re-

lationships with government agencies than citizens,

moved into the focus of attention and became the

main target for e-Government. In Germany, this shift

in focus has occurred under the heading of beneﬁt-

and industry-driven e-Government [92.6]. During this

phase, the integration of government and industry

processes became the main subject of e-Government ef-

forts, ultimately aiming at the seamless integration of

e-Government and e-Business on the ICT as well as on

the process level.

A common way to describe a project’s or even

a country’s maturity with respect to e-Government is

to position it on a scale comprising four phases, each

indicating the degree to which the potential of ICT is

utilized to deliver public services electronically [92.7]:

•

Presence. The emphasis in this phase is to offer on-

line static information about government agencies

and their services. In this phase, e-Government ser-

Part I 92.2

1632 Part I Home, Ofﬁce, and Enterprise Automation

Fig. 92.3 Interaction site for accessing land parcel information to be used for agricultural subsidy applications in the

German state of Rhineland-Palatinate (http://www.ﬂo.rlp.de)

vices are often limited to a presence on the web,

providing the public with information similar to that

of a brochure or leaﬂet. Meanwhile most public web

sites have gone beyond this stage.

•

Interaction. Solutions in this phase typically in-

clude simple forms of interaction; for example,

citizens can ask questions and receive answers

via e-Mail, download forms or search government

databases. The interaction phase is exempliﬁed

by the web-based system FLOrlp – Land Par-

cel Information Online for the German State of

Rhineland-Palatinate, which supports farmers in ap-

plying for agricultural subsidies by providing them

with precise information on the location and size

of their cultivated areas and by allowing them to

visualize areas by means of maps and aerial pho-

tographs [92.8](Fig.92.3).

•

Transaction. Conducting complete transactions on-

line, such as applying for passports, submitting

tax declarations, paying taxes and fees, or sub-

mitting bids for public tenders, are supported by

systems in the transaction phase. These solutions

are considerably more complex because often they

have to address technically challenging issues, e.g.,

concerning security and privacy. For instance, dig-

ital (electronic) signatures or equivalent methods

of identiﬁcation are necessary to enable legally

binding administrative acts. Often government even

needs to pass new laws to enable paperless trans-

actions. An example of an e-Government solution

requiring authentication of users through digital sig-

natures is the German federal procurement solution

e-Vergabe [92.9]. Additional examples of trans-

actional sites are shown on the following pages

(Figs. 92.4–92.7).

•

Transformation. Solutions belonging to the transfor-

mation phase represent the most advanced form of

e-Government. They comprise entire process chains

between government and its clients. The services

in the back ofﬁce are completely integrated so that

boundaries between different tiers of administration

(e.g., federal versus state), departments or agencies

are removed. The solutions are highly complex and

require the governmental bodies to be reorganized

in a new, process- and service-oriented way. This

stage harnesses the beneﬁts of ICT to their fullest

extent. Currently, solutions in the transformation

phase are still rare. However, within the European

Union, a majorboost for e-Government projects tak-

ing them to the transformation phase is expected

through the EU Services Directive. By 2010, this

regulation requires all member countries to offer

points of single contact and handle all processes by

electronic means for service companies which want

Part I 92.2

e-Government 92.3 Proceeding from Strategy to Roll-Out: Four Dimensions of Action 1633

Fig. 92.4 Transaction site for paying taxes in the state of Indiana (USA) (courtesy of Government Indiana,

https://secure.in.gov/apps/dor/iﬁle/2007/)

to set up businesses [92.10]. Also, many countries

already offer comprehensive portals for business

and citizens to access public services, such as the

UK Directgov portal (Fig.92.7).

In order to secure the success of e-Government devel-

opments, implementation activities need to proceed on

four dimensions. In the following section, we will look

at each of these dimensions in turn.

92.3 Proceeding from Strategy to Roll-Out: Four Dimensions of Action

Beneﬁt-driven e-Government projects beyond the com-

munication phase are characterized by a high level

of complexity. They usually span multiple and of-

ten autonomous organizations (public agencies and

companies), involve heterogeneous IT infrastructures,

and concern numerous target groups and stakehold-

ers. They have to meet conﬂicting requirements, face

complex technical dependencies, and have to respect

different legal constraints. Similar challenges also have

to be faced in other IT projects. What makes e-

Government projects special though is that they usually

have to cope with a combination of numerous inhibit-

ing factors and that IT strategies and decisions in the

public sector are closely related to political constel-

lations, which in democratic states may change from

one election to the other. For the successful execu-

tion of e-Government projects, it is therefore essential

to:

•

Develop a clear view of strategic objectives

•

Design projects so that tangible results become vis-

ible at an early stage for all parties

•

Involve users and stakeholders from the onset

•

Handle architectural tradeoffs in a transparent way

•

Ensure sustainability of the solution (in terms of

legal aspects, process and technology used)

•

Manage and minimize risks for all parties involved

•

Manage change processes for all parties involved.

Part I 92.3

1634 Part I Home, Ofﬁce, and Enterprise Automation

Fig. 92.5 Transaction site for requesting property taxes in the city of Bogota (Colombia) (courtesy of Bogota City Hall,

http://enlinea.catastrobogota.gov.co/)

In order to accommodate these aspects, the design

and implementation of beneﬁt-oriented e-Government

should proceed on four dimensions:

•

Strategy

•

Processes and organization

•

Technology

•

Project and change management.

We will now look at each of these dimensions.

92.3.1 Strategy

On the strategic dimension, a master plan has to be

created which addresses the following topics.

Political Objectives Pursued by e-Government

There are different objectives that can be the driv-

ing force behind the implementation of e-Government;

for example, e-Government can be used as a way

to enhance a community’s attractiveness for citizens

and business, as a means to increase the transparency

of democratic processes or to increase the efﬁciency

of the administration. In addition, the way in which

political and administrative institutions on different lev-

els of government interact needs to be spelled out.

In countries which are organized in a centralized

way, a more-or-less top-down approach is feasible,

whereas in countries based on a federal system there

is an obvious need to establish structures that regu-

late the complicated interplay of different stakeholders

and help to resolve controversial issues in a timely

manner.

Targets Addressed by e-Government

Based on the high-level political objectives, the primary

groups which are to be targeted bye-Government canbe

determined and prioritized, i.e., government itself, cit-

izens or companies. In order to arrive at an operational

level, these groups need to be broken down further;

for example, if a government decides to put the focus

on citizens, it may put emphasis on subgroups such

as elderly persons, immigrants or families. Similarly,

when targeting business, a decision can be made on the

Part I 92.3