A large global bank needed support to consolidate its regulatory reporting with BCBS 239 (principles for effective risk data aggregation and reporting). Brickendon was called upon to develop a mechanism to support the bank’s attestation to the regulator and provide a robust interpretation of the regulation itself to drive minimum standards of compliance.

The Challenges

  • Interpretation: to understand and correctly interpret non-specific regulatory principles to a high level of detail
  • Wide scope: the regulation impacted all material entities of the bank and the concept of materiality was not agreed
  • Legacy issues: significant problems in relation to fragmentation of the IT application landscape, challenges with data quality for reporting and reference data management
  • Lack of consistency: no consistent mechanism to report to the regulator and no minimum standards of compliance for the bank to follow
  • Resources: significant resource challenges with respect to budget, headcount and existing internal expertise
  • Regulatory conflict: different regulatory agendas (IFRS9, Ring Fencing, FDSF, Senior Managers Regime) competing for the attention of the same senior staff
  • Technical support: limited backing for the implementation of a technical solution
  • Conflicting priorities: existing focus on remediation work and limited expertise within the bank of the regulatory requirements

The Brickendon Solution

  • Develop a process for a consolidated, evidence-based summary of compliance for each principle of the regulation through deep-dive analysis of compliance by risk domain, services, business line and legal entity
  • Create a set of minimum standards agreed to by the business lines and a corresponding testing framework
  • Embed a culture encouraging the self-identification of issues and close liaison with second- and third-line independent validation teams
  • Implement governance forums to ensure the appropriate escalation of, and agreement on, divisive issues
  • Implement a proof of concept for tactical technical solutions to support the collation and reporting of the bank’s compliance evidence
  • Provide a team of industry experts who are flexible and self-governing to manage ad-hoc queries and provide senior stakeholder advice and consulting on the specifics of the regulation and industry trends
  • Provide an open solution, with limited technical burden and embedded self-quality assurance processes, facilitating the handover to low-cost delivery capability

Client Benefits

  • Simplification of a complex reporting requirement
  • Protection for CRO/CFO roles from the Senior Managers Regime (SMR)
  • Scalable and manageable reporting process
  • Minimum standards to ensure the bank does enough, but does not over spend on remediation activities
  • Clear ownership of remediation activities
  • Confidence in the reporting of compliance with non-specific regulation
  • A solution which is transferable to all non-specific regulation

To find out how Brickendon can help your business understand the regulatory requirements of BCBS 239, please contact us at [email protected] or call us on +44 (0)203 693 2605

We are an award-winning transformational consultancy with the drive, skills, knowledge and experience to help you change your business for the better. Let us show you what we can do.

By continuing to use the site, you agree to the use of cookies. more information

The cookie settings on this website are set to "allow cookies" to give you the best browsing experience possible. If you continue to use this website without changing your cookie settings or you click "Accept" below then you are consenting to this. To view our full policy click here

Close