Strategic Regulatory Reporting

An international tier-one bank was implementing a Trade Data Repository (TDR) and required advice, management and expertise across a variety of problem spaces. A large team had been assembled to work on various aspects across the platform and Brickendon was asked to provide expertise to develop solutions across the entire range of activities. The original technology solution evolved over time from a cache designed for near real-time post-trade reporting specifically for Dodd-Frank, to the de-facto post-trade data source for a range of external and internal consumers.

The Challenges

• Scale – 73 trading system instances in 27 counties producing more than a million trade events per day with over 100 normalised data elements each. This totalled 100M+ data elements per day, or 1,000+ per second, generating over 24,000 distinct data input/outputs every day.
• Demand – Required data outputs had differing formats, coverage and timing demands for multiple regulatory projects. This placed significant pressure on the central implementation and test teams with competing demands for time and resources.
• Visibility – Having evolved from more of a technical repository, various user interfaces were needed to provide visibility across the data for both internal and external use.
• Quality and Lineage – multiple reference data sources, complex booking models, and lack of clear ownership boundaries at the consumer end presented critical challenges for data integrity, completeness, timing and coverage.

The Brickendon Solution

Brickendon developed and supported a variety of solutions across this complex architecture and business landscape:

• Technical Architecture using technologies including Java, Oracle, XML / FIXML and FpML. The system allows for the caching and parallel processing of very large amounts of data consumed and produced. This was implemented across 48 servers in two locations, each with almost 200GB of RAM, providing 4.6TB of cache per site.
• Business Architecture to support the Functional Design for Trade Reporting to break down very complex demands into implementable steps and provide a regulatory agnostic approach to all stages of the delivery from identification and preparation, eligibility and obligation, content creation and masking, and submission and exception management.
• Consumerisation of the data to reduce reliance on limited technical resources by providing a self-service facility for users to build their own data extracts and feeds to support their individual needs.
• Change and Release Management across a complex network of competing priorities, creating the pipeline of work for new regulation and driving compliance from requirements capture, through development, testing, dry-run coordination with the regulator, defect remediation, and go-live.
• Business Analysis to translate external regulations and internal demands into clear requirements for technology teams.
• Delivery management of data from source systems to ensure accurate and timely data is fed to the data cache in line with consumer, regulatory, or internal demand.
• Defect management to tackle a backlog of over 800 anomalies, including triage, regulatory impact assessment, prioritisation, and mitigation as needed in order to efficiently allocate resources for maximum impact of remediation work.
• Pre-trade advisory platform designed, developed and delivered to support traders and other front office staff. Initially covering requirements from EMIR and CFTC rules under title VII of Dodd-Frank for Rates, but then extended to include EMIR Mandatory Clearing rules, FX, Credit and Equity OTC Derivatives, and block trading.
• Data Exploration Tools designed, developed and rolled out to allow all involved to clearly view the data lineage, quality and attribute-level coverage from the original trading platform data, through translations and mappings into the standard data representation used by end consumers.
• Data Quality Framework to ensure that information feeding into the Trade Data Repository was complete, correct and timely. This included both daily automated controls and change management controls to guarantee quality over time.

Client Benefits

• End-to-end management of all teams involved in delivery allowing us to partner with the client to identify and implement cost savings and efficiencies, including flexible resourcing to address time-critical issues and simultaneously address seating limitations via our B-FIELD near-site facility.
• Standardised approach to all Trade Reporting demands regardless of regulation or jurisdiction, increasing efficiency, decreasing time-to-market and reducing future change cost. Initially implemented for liquidity-related reporting to BoE and ECB and subsequently extended for SEC and MiFID II.
• A clear vision for the platform, including loose coupling of producers and consumers, full event coverage, single formats per product, early transformation into a standard format, and clear data ownership and governance.
• Complete, Correct and Timely data available, providing confidence that the central repository is the fastest and most reliable source of data to meet enterprise, regulatory and other consumer needs.
• Cost savings have been significant with the new strategic repository providing multi-million-pound savings in infrastructure costs, significantly reduced project delivery costs, and acceleration of decommissioning programmes of a number of legacy platforms. Multiple independent programmes have reported 80-90% cost savings when leveraging the central strategic repository, rather than point-to-point solutions.
• Faster time-to-market for new trade-related regulatory change requirements. For example, a project to monitor FX transactions not executed at the prevailing market price to mitigate the risk of potential compliance breaches and reputational damage was implemented in nine months from start to finish across 13 locations (instead of nine months for each location as previously estimated).
• Change and release management that provided clear traceability and transparency for stakeholders throughout the delivery lifecycle to ensure that compliance was clearly evidenced.
• Visibility for front-office staff via a portal to provide up-to-date decision support for trading activity across a changing regulatory environment. Also provided end users with a clear view of their data, showing coverage, lineage and quality of data used to meet external regulatory demands.