Regulatory Compliance

BCBS 239 – Tips on how to get your next IT-development or application PERDARR ready

3-minute masterclass

Last June we were in London attending the Vermeg Annual Regulatory Reporting Conference. There Giancarlo Pellizzari, Head of the Banking Supervision Data Division of the European Central Bank (ECB), emphasised that the ECB will pay more attention to data quality. This was not a surprise as last year we spoke to one of the ECB’s head of the inspection teams and he mentioned that this (data quality) would become a prime focus for the ECB in 2019. And rightly so. Today’s data delivered by financial institutions to the ECB is often of poor quality.

A big part if the issue has to do with the cultural mindset of the institutions, which will be the subject of a different article. For now, we’d like to give you some tips and tricks on how to get your next IT-development or application purchase PERDARR (principles for effective risk data aggregation and risk reporting) ready. It’s not rocket science, it is a case of just doing it.

The history of data

When you talk data, many people think label, value. But this is way too limited. All data has a source and a history, how will you ever be able to verify and reconcile your data when you don’t know where it came from? Or who or what transformation improved it, and on top of that when it was improved?

The data date

Knowing when you did an update is of great importance, especially when you’d like to reproduce data and the auditor comes around and asks uncomfortable questions. But keep in mind that this will only be relevant if (1) the data date is a report input variable and (2) the old report is still available. This might not be in your daily work environment, but you must be able to reach it.

A measure to explain its completeness

Every report should come with a measure explaining its completeness. How many records are shown, how many aren’t? What makes sense really depends on the context of the report. Asking yourself and the developers this question will help you think beyond the happy flow and will allow you to detect disruption of quality issues far earlier in the periodic delivery process. And this is definitely something you’d like to know, right?

Good luck with the implementation! If you need a helping hand or more information, we’re always up for a good chat!

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