CRD IV and EBA reporting BUSINESS & DECISION RISK TECHNOLOGY CONSULTING
Jun 14, 2015
CRD IV and EBA reportingBUSINESS & DECISIONRISK TECHNOLOGY CONSULTING
• Supervisory reporting requirements applicable to credit institutions as from 2014– EBA released ITS directly applicable without further transposition– Extended COREP and revisited FINREP reporting requirements– New XBRL taxonomy and data point model released at EBA level to further harmonize process
• COREP– Own funds and own funds requirements– Losses stemming from lending collateralized by immovable property– Information on large exposures– Leverage ratio– Liquidity reporting– Reporting on asset encumbrance– Forbearance and non performing exposures
• FINREP– Reporting on financial information
The regulatory contextHELICOPTER VIEW OF UPCOMING COMPLIANCE REQUIREMENTS
The actual challenge
• It does not happen at the credit department anymore• It becomes a true data challenge with increased focus on sourcing, quality and monitoring• Shared governance and increased involvement of finance and treasury to make it happen• Genuine enterprise-wide risk understanding, interpretation and measurement 'capabilities• Next to a solid reporting platform there is a need for increased assistance in business consulting and
downstream conversion / execution
BASEL III AS ACCELERATOR FOR NEEDED CHANGE
You might want to ask yourself…
• How will we be able to meet both the implementation guidelines and greater frequency and granularity of reporting?
• How are we going top cope with the significant additional reporting burden and can current infrastructure support it?
• What will the post-COREP risk and finance operating model look like?
• How will we capture the additional data required effectively and ensure appropriate controls have been applied around quality of content?
• What other regulatory changes do we need to manage in parallel?
UNREVEALING KEY CONSIDERATIONS ONCE YOU DIG A BIT DEEPER
• Regulatory interpretation– Although some of the reports are well known (i.e. risk classes, capital adequacy…) others are new
(i.e. liquidity reporting) and might lead to confusion in terms of meaning• Implementation timelines
– The Q1 2014 deadline provides a remaining implementation timeline of just a few months which should include all testing and assurance on the new process
• Risk and finance operating model– Risk and finance functions must work closely together to ensure deep understanding of the
underlying information and provide clarity over who signs off on data and reports
• Data availability and governance– The reporting function in finance will have greater responsibility on providing and attesting to risk
and other data contained in the COREP reports– Granularity of data in COREP may require additional fields to be created in source platforms– Consistent data definition across increased landscape will be required– Greater reconciliation and other control measures will be needed
Dependencies…THAT ARE NOT BEING ADDRESSED WITH A TECHNOLOGY SOLUTION
• True complementarity and leverage of a long-lasting relationship with reporting solution vendors for both banking and insurance market across different levels of collaboration
• The combined service offering of software vendors and B&D allows customers to take advantage of our consulting services beyond reporting and ramp up the chain– Conducting readiness assessments with tools developed over a number of years– Expertise in development of reporting data models and reporting solutions– Data acquisition capabilities to merge data from multiple disparate systems with cleansing and
transformation– Training and change management expertise to embed process changes in the business– Specific regulatory, technology, data and project leadership expertise to lead and support delivery
Why considering another service provider?COMPLEMENTING SERVICE OFFERINGS ALLOW A 360° APPROACH
• The implementation challenges are significant and time to implement extremely short
• Informed decision-making on the preferred implementation approach as well as identification of data challenges and a robust technology solution will allow you to optimize your implementation
• There are a range of non-competing and highly complementary services to be delivered right in between your preferred systems integrator and your reporting solution vendor.
• A “wait and see” approach is likely to negatively impact your ultimate ability to comply in an area of increased regulatory complexity
• We´d be delighted to meet you person to deepen some considerations and challenge your present approach to compliance
ConclusionCLOSING THOUGHTS AND FINAL RECOMMENDATION
• Risk-specialists with emphasis on– Broad business domain understanding
(Financial Services, Banking, Insurance)– Educated and well-trained business knowledge on
risk management and regulatory frameworks– Business intelligence concepts, methodologies
and tools (data warehousing and data governance)
– Both project management experience and certification (Prince II)
– Understanding of banking technology solutions and most common software packages
• backed by +2000 BI profiles throughout the B&D group
A glimpse at our delivery consultantsA RISK COMPETENCE CENTER IN THE HEART OF AN INTEGRATOR
Data extract
• Multiple source systems• Internal data sets• External data
requirements for Basel III calculation and internal reporting needs
Collection
• ETL - collect and transform the required data
• Store for processing in single location in logical data model
• Data quality and governance
Preparation
• Data aggregation in a Basel III context
• Setting up of financial information integration marts
Calculation
• Calculation of capital requirements
• Aggregation• Calculation of new
capital ratios
Reporting
• Existing financial reporting
• MIS and financial control• Legal reporting• XBRL conversion
What makes us different?INCREMENTAL VALUE CONSULTING APPROACH ACROSS THE FULL CHAIN
Gap analysis
• Scoping of assignment• Business review• Approach and expected
outcome• Internal organization• Regulatory and
business context
Inventory
• Governance, processes and controls
• System, standards and technologies
• Existing thoughts re B3 architecture
• Inventory of risks and K ratios
Target
• Target ratio calculation and/or aggregation approach
• Target organization (RACI matrix)
• Reporting (internal and legal) and financial control
Scenarios
• Strategic vs. tactical solution and leverage potential
• Project risks; cost vs. benefits assessment
• Technology choice and rationale
Action plan
• Preferred scenario roll-out plan
• Project initiation phase (PRINCE II)
• Project and solution KPI's• Maintenance, handover
and production
The EMEA Risk PracticeA ONE-STOP SERVICE PROVIDER
Discovery Phase
Gap AnalysisMaster Plan
Solution delivery Phase 0 … phase n Support
Introduction to our capabilities and cost/benefits
discussion
Solution Architecture
Business ProcessDesign
Information Management
Technical Architecture
Application Architecture
Solution Delivery
Infrastructure and applications
ETL and reconciliation
ERM Risk engines
Training, testing and QA
Disparate data sources
Organization & processes
Inadequate applications
Data governance
Analytics & reporting
Solutions
Post deployment support and
services to sustain success
Understand what is in place, what has been realized and
road map
Business & Decision provide technology and services to create capabilities required by the regulation and beyond based on the
client specific needs
Ongoing support and optimization in order to facilitate deployment
Maintenance
Perform gap analysis,
interviews across dept., formulate
and quantify needs, design solution and
create a master plan for delivery
Challenges
Find out whether and where B&D can add value
Engagement
Follow us!We would be delighted to help you address the challenge
Benoît BerckManager Banking RiskEMEA Risk Practice [email protected] +32 (0)491 86 89 00
Philippe MeyerDirectorEMEA Risk Practice [email protected]+32 (0)476 97 67 82