Transforming data collection – Reporting Transformation Committee minutes - September 2021

The Reporting Transformation Committee will focus on overseeing the design of solutions for parts of the reporting process where the Bank, FCA and reporting firms interact directly. This will cover aspects of modernising reporting instructions and creating a better integrated end-to-end reporting process.
Published on 08 November 2021

Date: 14 September
Location: Microsoft Teams

Minutes

Introduction

AS welcomed all to the meeting and recapped the actions from the previous meeting (approval of the minutes and Chair nominations). AS then asked AD, who was confirmed as Chair, to introduce himself to the group and explain his aims for the Committee.

Form DQ background

DF presented to the group about the Form DQ use case – explaining the purpose of the reporting, the reporting issues that have been highlighted during the discovery phase and options for improvement being investigated.

Key Discussion Points/Comments:

  • Members were keen to understand better the past ONS review of EMIR reporting, including the data gaps of concern to ONS and why de-duplication issues common in EMIR reporting were not seen in Form DQ.
  • Members wondered whether EMIR reporting and Form DQ could be more harmonised, or if the EMIR data could just be leveraged for the Bank’s purposes.

Action: DF said she would send round a link to a paper by the ONS about EMIR data.

Action: DF offered to share the preliminary analysis by the use case team from discovery work.

Project Plan

AB presented the project plan for the programme’s initial nine months, with separate use case workstreams and planned efforts to scale the reforms. He explained the key milestones in the life of a use case, including the analysis week at the end of the discovery phase, which will lead to a set of (prioritised) statements about how to approach solution design. The alpha phase of developing prototypes would then begin.

EM also presented on the discovery work around the Form DQ use case.

Key Discussion Points/Comments:

  • Members warned about the risk of the programme trying to do too much at one time, which would risk the programme failing to deliver on its aims. They asked whether use cases (e.g. RegData) should be pushed back.
  • AB explained that the resource of the delivery groups is split into teams working separately on the different use cases, in order to work intensively and cohesively on those. The Form DQ lessons have offered lessons for later use cases - this should facilitate faster progress.

External initiatives impacting

EM presented information gathered from the Delivery Groups about other external initiatives that affect the Form DQ use case. Synergies were identified with similar projects such as the EBA’s BIRD and the EMIR refit. EM asked the group if they felt other initiatives were relevant.

Key Discussion Points/Comments:

  • Members mentioned the Dear CEO letter from the PRA to firms about the quality of regulatory reporting. The TDC programme has a role in helping to eliminate these issues.
  • Members also mentioned the changes to the regulatory framework after Brexit. There is potential for EMIR to change after Brexit and those could impact Form DQ. EMIR affects a lot of firms, but Form DQ less so. There will be different effects on firms from changes to requirements.

Comms framework

AM explained that the programme was preparing updates to the website and communications to the industry, explaining the structure of the programme and recent progress. These communications are planned for late September.

Risks and issues

SH presented on the Risks and Issues for delivering the project in the near term. The most significant risks the programme team is currently either clarifying or monitoring are availability of resourcing, opportunities to scale the project and delivery of tangible outputs within our planned timescale of nine months.

Key Discussion Points/Comments:

  • Members queried whether for large use cases it would be better to split work into staggered stages. The programme team responded that it was necessary to do the discovery work thoroughly (in one block) to create the requisite evidence base about which ideas to move forward with.

AM then presented the Risks and Issues for the project’s long-term success. These included the risk of insufficient stakeholder buy-in, continuity of knowledge/people, ensuring implementation of project outputs and finally lack of available resources. AM asked whether the Committee were concerned about other risks.

Key Discussion Points/Comments:

  • Members raised concern about the risk of changing regulatory priorities. There have been recent developments in regulation, such as the inclusion of ESG and cryptocurrency risks in the regulatory framework, and further such changes might disrupt the programme.
  • Members said that it was important proposed mitigants for the risks fully considered the role of the regulators in mitigating the risks, and not just the industry participants.
  • Members spoke of the need to consult the whole market (including trade associations that represent many smaller firms) about any solutions that the Committee wanted to implement.
  • Members warned about the risk of deviating from global standards that are emerging. This could have unintended consequences for the industry.
  • AM reminded the group that anything that the regulators wanted to actually mandate would automatically be subject to formal consultation. Some members were concerned that the loudest voices make the most impact during consultations, which are often narrow in scope, and do not consider issues in depth. AB explained that the way consultation with the industry works will also be considered by this programme.

Forward agenda / AOB

RD and AM presented on the forward agenda and the dates of the upcoming meetings.

AD asked if the programme team could provide a brief summary of what the use cases are. AS said that he would provide this.

AS said that he would send out a request for the group to provide details of their exposure to the priority use cases, to ensure that the Committee had sufficient attendees for discussions of these use cases in the coming months.

Some members asked for clarification about the scope of the RegData use case and the experience that would be required. AS agreed that the programme needed to come up with a more precise description of the use case and the experience sought for the discussions.

Action: AS to provide Chair with descriptions of the use cases.

Action: DSC members to send short descriptions of their experience in the priority use cases to the TDC Secretariat.

Actions agreed in this meeting

  1. Secretariat to send RTC members information on the Board’s composition.
  2. RTC members to provide feedback on the committee meetings to date.

Attendees

Ffion Acland (FA), Goldman Sachs

Julian Batt (JB), Bank of America

Andy Beale (AB), Financial Conduct Authority (Interim TDC Programme Manager)

Rebecca Ding (RD), Financial Conduct Authority (Transformation Programme Lead)

Andrew Douglas (AD, Chair elect), Depository Trust and Clearing Corporation

Dayo Forster (DF), Bank of England (Product Owner)

Dawd Haque (DH1), Deutsche Bank

Sharon Howells (SH), NatWest (TDC Project Manager)

Paul Jones (PJ), Nationwide Building Society

Elizabeth Maloney (EM), JP Morgan (TDC Project Manager)

Farhiya Mohamuud (FM), Lloyds Banking Group

Angus Moir (AM, Chair), Bank of England (Transformation Programme Lead)

Lewis Reeder (LR), BNY Mellon

Aaron Shiret (AS), Bank of England (TDC Secretariat - Data Standards)

David Shone (DS), International Securities Lending Association

Ian Sloyan (IS), International Swaps and Derivatives Association

Tammy Solomon (RS), Investec Bank Plc

Nicholas Steel (NS), Barclays Group

Emma Tan (ET), JP Morgan

Andrew Turvey (AT), Belmont Green

Richard Young (RY), Bloomberg

Apologies

Caroline Lewis, Lloyds Banking Group

Liz Henderson, NHBC

David Holland, Coventry Building Society

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