Date of meeting: 2 November 2021
Location: This meeting took place via Microsoft teams
The joint transformation programme is publishing its committee minutes. These materials are published in the interests of transparency. Any opinions, proposals or policies contained in them are those of the joint transformation programme or, as the case may be, its groups, committees or individual members. They do not represent the opinions, proposals or policies of the Bank of England, the FCA or other participants and they should not be taken as an indication of future policy. Information that is confidential or commercially sensitive has been omitted.
AM opened the meeting and gave apologies for Gareth Ramsay who was unable to attend. IP explained the agenda.
Terms of Reference
IP invited the Board to review the TDC programme’s Terms of Reference, which apply to the Board. IP invited members with comments to send them to the Secretariat.
Action: Members to send comments on the ToR to Secretariat by 16 November 2021.
Vision for Transforming Data Collection and Board
IP asked the Board to consider what the ideal reporting process would look like in ten years’ time, the benefits this would deliver and the role of the Board in that transformation.
Key Discussion Points/Comments:
- Members emphasised that reporting is just a process aimed at producing an outcome – delivering data for users at firms and regulators that are gathering information. Members said any changes to the reporting process must improve that outcome.
- Some members emphasised the need for a paradigm shift in how reporting happens. They felt this paradigm shift should allow far greater flexibility in collections. SC described the future reporting process allowing authorities to answer ‘the unexpected question’. Some members described what that future state might look like. They described a world of data residing in curated datasets rather than in reports, with authorities allowed to access that data under specified conditions.
- Other members focussed on the need to streamline what data is collected. PB thought that regulators need to overcome the mindset that there is always benefit from additional data. He felt reporting should be more coherent but more streamlined.
- Members discussed who might be the beneficiaries of a transformation of data collection. SOM stated the importance of considering all relevant stakeholders, particularly market participants, who stand to benefit from increased data transparency.
- Members agreed that a key function of the Board will be holding the Joint Transformation Programme accountable – ensuring it has a clear purpose, achieving its objectives etc.
- Members agreed that the programme needs a clear approach to transforming data collection, based on a set of defined principles. They felt the board had a role to play in defining and publicising these principles. SS mentioned the FAIR Guiding Principles for scientific data management and stewardship as a useful comparison.
- Members commented that the Bank/FCA should further clarify the Board’s remit. They also thought the Board should articulate a vision for the project.
- AM summarised the actions for the programme.
Action: Secretariat to develop a framework for measuring the progress/benefits of the programme.
Action: Secretariat to produce an initial draft of design principles for the programme’s outputs, for the Board’s consideration.
Pre-mortem for Transforming Data Collection and Board
IP asked the Board to imagine that in ten years’ time the programme had failed to achieve a transformation, and suggest what would be likely to have caused this.
Key Discussion Points/Comments:
- Members reiterated their view that work on transforming data collection should have a set of well-defined objectives. They felt these objectives should be measurable and that tracking the programme’s progress against its goals should be based on evidence. They felt a key role of the Board is to define and track these measures. CR2 suggested that the programme could express its objectives as a granular set of goals, rather than as one big ambition. RK suggested that the Board repeatedly redefine these objectives in response to developments.
- Members discussed how to ensure that the scope of the work is both clear and manageable. CR2 suggested that a goal of ‘transforming data collection’ is too broad. He suggested that the programme participants will need to decide on the extent of their ambition for the different elements of the programme. For instance, he felt the Board will need a strong sense of which goals will need ‘transformation’, and which will just need ‘improvements’.
- Members agreed the programme’s focus should be on removing the elements of data collection that create inefficiency, rather than building new collections intended to be more efficient.
- Some members emphasised the need to get firms to ‘buy-in’ and show benefits to firms beyond regulatory reporting. For instance, RA spoke about the need to produce and show benefits to firms beyond regulatory compliance. He felt there are group-wide technology and data benefits from the transformation programme. He felt that excessive focus on regulation would risk isolating the programme from relevant stakeholders.
- AA warned of the costs of regulation and the risk that industry passes this on to customers. He also proposed that the project tracks ongoing developments in relevant technology.
Joint Transformation Programme update
RD1 presented the programme’s conceptual view of how transformation should work – ‘pipeline management’ first, then ‘discovery and design’, ‘decision and challenge’ etc. She explained the different elements of the programme structure, including the roles of the different governance and delivery groups.
AM gave an update on the project plan, including the status of the discovery and design work. He explained that a key element of the plan is work aimed at scaling-up the solutions e.g. when tackling CRE issues, considering whether the solutions emerging may also apply to mortgages.
LA asked for clarification about the relationship between the Board and the rest of the programme. IP suggested that the programme could make this clearer and that the Terms of Reference may be the best way to do this.
Action: Secretariat to consider need for clarification of the ToR and confirm next steps.
Chair nomination process
AM explained that over the longer term, the Board will have a Chair from industry. He explained the process for choosing the Chair. If participants wish to be the Chair, they should nominate themselves. The Board will then vote on the nominees.
Action: Participants who wish to nominate themselves should send a short statement to the Secretariat explaining their suitability by 16 November 2021.
Actions agreed in this meeting
- Members to send any comments on the ToR to Secretariat by 16 November 2021.
- Secretariat to develop a framework for measuring the progress/benefits of the programme.
- Secretariat to produce an initial draft of design principles for the programme’s outputs, for the Board’s consideration.
- Secretariat to consider need for further clarification of the ToR and confirm next steps.
- Participants who wish to nominate themselves should send a short statement to the Secretariat explaining their suitability by 16 November 2021
Ankur Agrawal (AA), AXA
Luke Ashton (LA), Barclays
Roshan Awatar (RA), Lloyds Banking Group
Paul Barrett (PB), AIG
Andy Beale (AB), Financial Conduct Authority (Interim TDC Programme Manager)
Paul Chambers (PC), Standard Chartered
Samik Chandarana (SC), JP Morgan
Charlotte Clark (CC), Association of British Insurers
Graham Cohen (GC), BNY Mellon
Rebecca Ding (RD1), Financial Conduct Authority (Transformation Programme Lead)
Richard Dunne (RD2), RSA Group
Lee Fulmer (LF), UBS
Alastair Hall (AH), Legal & General
Rakshit Kapoor (RK), Santander
Shane Kingston (SK), Brit Insurance
Angus Moir (AM), Bank of England (Transformation Programme Lead)
Scott O’Malia (SOM), International Swaps and Derivatives Association
Adrian Pearce (AP), Credit Suisse
Ian Phoenix (IP), Financial Conduct Authority (Director of Intelligence & Digital)
Corinne Powley (CP), Phoenix Group
Elaine Priest (EP), NatWest
Charles Reindorf (CR1), Bank of America
Charles Resnick (CR2), ClearBank
Aaron Shiret (AS), Bank of England (TDC Secretariat)
Simone Steel (SS), Nationwide Building Society
John Tierney (JT), Nomura
Matthew Tyrrell (MT), Financial Conduct Authority (Senior Manager, Central Data Services)
Gareth Ramsay, Bank of England (Executive Director of Data & Analytics)
David Palmer-Lewis, Principality Building Society
Andy Parsons, Just Group