Date of meeting: 1 February 2022
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.
Actions agreed in this meeting
Secretariat to contact Companies House to understand their position on issuance of the LEI.Secretariat to add item to a future agenda for further discussion of mandating the LEI.Secretariat to invite committee members to solution design workshops.Secretariat to identify appropriate opportunities to delegate decisions to working groups.
AD welcomed all to the meeting. AS recapped the actions from the previous meeting (Secretariat to: circulate list of firms interviewed for CRE workstream, commission Data Standards Review and add item to DSC agenda on role of the Board). AS confirmed the three actions taken. The Committee confirmed its approval of the minutes from November.
Project plan update
AB presented a progress update. Use case workstreams are in Alpha and solutions are in varying stages of design and testing. The key challenge currently is the constraint on resource. The delivery team has developed a framework for explaining the investment case behind solutions – they will test this with the FRS workstream.
The project RAG status is currently Amber, mainly due to the rate of progress on use case prototypes. To return to Green status, we will prioritise further the solution features.
AD encouraged any DSC members not yet involved in design and testing workshops with the delivery teams to volunteer.
Commercial Real Estate alpha solutions
SH presented one of the solutions emerging from CRE work – the use of identifiers to enable the creation of a Single Customer View. CRE data suffers from a lack of clear data definitions and instructions for calculations, and a lack of consistency in the design of reporting. Using customer identifiers for reporting CRE exposures would allow the Bank to match real estate risks to specific entities.
There were two options for the use of customer identifiers – developing a way of using existing identifiers for this purpose, or creating a new identifier for firms to use. The Committee preferred to make use of existing identifiers – there was no support for creating a new one.
SH explained the delivery team’s proposal for using existing identifiers. For customers that are incorporated entities, there were two options - regulators mandate that firms collect LEIs, or give firms the option of using LEIs where available and other identifiers for the remaining customers. Furthermore, for unincorporated customers, either the regulator could create a register of customer identifiers to use, or firms could use existing tools offered by the Bank, ONS etc. SH demonstrated a prototype illustrating how this combination of methods to source identifiers would work.
Key discussion points / comments:
- Members strongly supported efforts to maximise use of the LEI, with some members supportive of a regulatory requirement to use it. Members commented on the already extensive use of the LEI. Most organisations with LEIs are financial services firms or those transacting with them, for example in derivatives.
- Other members were opposed to a regulatory requirement, commenting that requiring counterparties to have LEIs to access finance has the effect of a tax on finance. Firms’ smaller borrowers would pay a lot of the incremental cost of the requirement. AT asked that regulators consider proportionality e.g. only mandating it for use with bigger borrowers. GC commented that a transition period for implementing a requirement would help alleviate the implementation burden.
- AD commented that it was a suitable long-term goal for counterparties to have LEIs, but that a short-term solution will enable progress on this issue. DH1 commented that as the industry is still evolving towards use of the LEI, a hybrid solution, making use of other resources such as the ONS classification would work for now.
- In response to concerns over cost and adoption, some members commented that our focus should be on removing barriers to LEI adoption if we think that the LEI is ultimately the strategic solution. Members thought Companies House has a key role to play, as it already issues companies with registration numbers and there would be a synergy if it also issued LEIs. Members asked that the Bank speak to Companies House about the issue. AS confirmed that the programme would contact Companies House to understand their position.
- Members spoke of how a lack of regulatory requirement is itself a barrier to adoption. Where jurisdictions have mandated the use of the LEI, adoption has happened far quicker than would otherwise have happened.
- AM explained that the Bank was not opposed to mandating the use of the LEI, but that there needed to be a clear business case for doing so. He also mentioned that HMT would be a relevant stakeholder.
Action – Secretariat to contact Companies House to understand their position on issuance of the LEI.
The committee also discussed a second question around opportunities to scale such a solution. For example, the programme could build a solution incorporating both customer identifiers and counterparty sectors (a proposed solution for Form DQ). Some members reiterated their hope that Companies House would have a role in issuing LEIs, as this would scale up the benefits. The committee made further comments supporting the use of LEIs, including mandating LEIs, as their preferred solution, believing this to be the focus.
AD suggested that due to the group’s strong preference for expanding use of the LEI, the committee would have a further discussion on mandating the use of the LEI.
Action – Secretariat to add item to a future agenda for further discussion of mandating the LEI.
Cross-use-case solution – Data Dictionaries
AB presented a solution proposed by all of the use case workstreams – increasing use of data dictionaries. AB explained that data dictionaries capture metadata; they document and define data to creating common meanings. The programme has repeatedly identified a need for common meanings for attributes, so an accessible location for finding agreed definitions would be useful. The committee discussed whether data dictionaries should be a priority solution and the challenges that could arise in design and implementation of this.
Key discussion points / comments:
- The committee agreed that data dictionaries would be beneficial.
- DH1 commented that trying to achieve data dictionaries for prudential and financial reporting or for multiple use cases, would involve much greater complexity.
- Members suggested ways to design data dictionaries, such as modelling them on existing standards with useful definitions. CL warned against creating widely applicable data dictionaries based on reports with limited scope of application – this would result in dictionaries tailored to a narrow group of firms. To solve this we could create multiple dictionaries rather than one unified dictionary.
- Some members suggested that data dictionaries could be costly, and suggested that regulators reduce such costs by allowing firms to comply subject to materiality thresholds. Other members however raised concerns that this would detract from the purpose of the standard and compromise the accuracy of aggregated numbers, where a subset used different definitions. They suggested alternatively that firms could send regulators both their data and an explanation of the calculation instead.
- AD said that the committee would revisit this issue of whether firms should send regulators their data accompanied by an explanation of its preparation.
- Members suggested using various existing industry standard taxonomies to build data dictionaries, to minimise the disruption of implementation.
Form DQ update
EM presented an update on the workstream. Three teams are currently working on solutions for Form DQ – counterparty classification standardisation, standardising Form DQ attribute definitions and improving regulatory communications. EM encouraged committee members to participate in forthcoming workshops with the delivery team to shape solutions.
EM also highlighted that the workstream had recently prioritised some solutions and paused work on others, such as improvements to the quality assurance process and moving to curated datasets rather than templates. These are more long-term ambitions, whereas the priority solutions seek to fix problems that are more fundamental.
DF presented the programme’s methodology for scaling solutions. Scaling involves both ‘conquering’ bigger solutions and taking smaller solutions to a bigger scale. The scaling team will consider how scaling interacts with the delivery work at various stages during the process. This will include engaging with the project teams when they prioritise features, and identifying alpha solutions that could apply more generally.
Role of the Board
AS gave a presentation about the role of the Board, as previously requested by DSC members. The Board’s role is to represent the voice of the industry at the senior level, and advise on how the programme as a whole can be effective. This includes setting the programme’s goals and discussing long-term planning considerations such as resources and investment.
Forward agenda / AOB
AS presented the group’s forward agenda, with the next meeting scheduled for early March. The next meeting of the Board is also coming in mid-March. AS explained that the remaining Phase 1 meetings would consider the investment case for proposed solutions and make final recommendations. They would also consider scaling of solutions, planning for implementation of recommended solutions, and the use cases for Phase 2 of the project.
AS encouraged the committee to sign up for delivery workshops and committed to circulate the dates of these when available. Members asked whether it was possible to delegate any decisions to the working groups. AS committed to identify appropriate opportunities to do this.
Action – Secretariat to invite committee members to solution design workshops.
Action – Secretariat to identify appropriate opportunities to delegate decisions to working groups.
Ffion Acland (FA), Goldman Sachs
Julian Batt (JB), Bank of America
Andy Beale (AB), Bank of England (TDC Programme Manager)
Chris Caldwell (CC), Financial Conduct Authority (Transformation Programme Lead)
Gabriel Callsen (GC), International Capital Market Association
Andrew Douglas (AD, Chair), Depository Trust and Clearing Corporation
Dayo Forster (DF), Bank of England (TDC Scaling)
Lee Fulmer (LF), UBS
Dawd Haque (DH1), Deutsche Bank
Dave Holland (DH2), Coventry Building Society
Sharon Howells (SH), NatWest (TDC Project Manager)
Caroline Lewis (CL), Lloyds Banking Group
Elizabeth Maloney (EM), JP Morgan (TDC Project Manager)
Angus Moir (AM), Bank of England (Transformation Programme Lead)
Gemma Poddington (GP), Credit Suisse
Corinne Powley (CP), Phoenix Group
Fabiana Saponaro (FS), Financial Conduct Authority
Aaron Shiret (AS), Bank of England (TDC Secretariat)
David Shone (DS), International Securities Lending Association
Ian Sloyan (IS), International Swaps and Derivatives Association
Tammy Solomon (TS), Investec
Emma Tan (ET), JP Morgan
Andrew Turvey (AT), Belmont Green
Martin Udy (MU), Bank of England (TDC External Engagement)
Rebecca Whitwam (RW1), Bank of England (TDC Secretariat)
Ian Wilson (IW), Nationwide Building Society
Richard Young (RY), Bloomberg
Rich Evans, FIX Trading
Nicholas Steel, Barclays