Date of meeting: 29 March 2022
Location: 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 arrange deep-dive session for the committee with the Form DQ delivery team to go through the draft recommendations.
- Delivery team and Secretariat to circulate recommendations documents to the Committee.
AS welcomed all to the meeting and introduced the agenda. The Committee confirmed its approval of the 1 March minutes. AS recapped the action from the last meeting – the Secretariat had invited committee members to working groups with delivery teams.
Project plan update
AS presented a progress update. Form DQ solutions are in testing but at a sufficiently mature stage that the team can present draft recommendations for the workstream. The Bank and FCA recently met to discuss the CRE data use case and agreed that the programme should move this data collection area away from its status quo.
Regarding scaling of solutions, the programme team has created a set of criteria that all features must meet before TDC will scale them. Furthermore, it has agreed a set of features from the alpha work to prioritise for scaling, such as a new structure for reporting instructions and the standardisation of counterparty classification.
The programme team has amended the project plan, giving several more weeks for the completion of the Phase 1 work, including recommendations. The team has also extended the period after Phase 1 for regulators to respond to the recommendations and plan their implementation, as this looks likely to be a detailed piece of work.
Recommendations finalisation process
AS explained the plan for agreeing the committees’ recommendations for Form DQ (and FRS). At this meeting, the Form DQ team will present their draft recommendations. In the coming weeks, they will then (via the Secretariat) circulate a formal draft of the recommendations proposal to the committee. The committee will then have time to read the draft and propose changes. The Secretariat will work with the delivery team to create an updated draft, which they will then circulate again for any final committee comments and approval.
The committees will publish their recommendations and the Bank and FCA will consider their response. In making any decisions about changing their data collection operations, the regulators will need to go through internal governance. They will then publish their response to the recommendations. The programme team will keep a regular cadence of meetings with the committees during this period, and will consult the committees as appropriate, including feedback on consultation papers that may be required.
Form DQ draft recommendations
EM gave an introductory presentation on the recommendations from the Form DQ workstream. She began with a reminder of the problems highlighted by the discovery phase. Regarding the previously presented ‘counterparty classification’ solution, she explained the proposed recommendation – the BOE should create and maintain a matrix that standardises counterparty classification by mapping reference data to industry classes. As a ‘quick win’, the BOE ought to develop a decision tree prescribing how to classify counterparties. In the medium term, it should build a strategic solution allowing the automation of the classification process.
Key discussion points / comments:
- Members suggested that in the reference data for the mapping matrix, the Bank should use NACE, as well as SIC and other proposed reference data.
- IS commented that the solution would help improve existing processes, but thought that moving towards greater use of common data standards would make more long-term sense. Some market initiatives require entities to share all their reference information with their counterparties.
- AT suggested that the FCA was a better long-term home for this initiative given its role in overseeing EMIR derivative reporting requirements.
EM continued by presenting a draft recommendation relating to Form DQ attribute definitions and data standards. The team proposes that the Bank reformat existing instructions and data definitions so that they are more user-friendly, with data definitions in tabular format.
The draft recommendation suggests that the Bank then works on a strategic solution, with prescriptive definitions that include required international standards. Such a proposal might require consultation. In the long term, the delivery team proposes that TDC should continue working on development of a logical data model.
Key discussion points / comments:
- TS expressed concern about the effect of the proposal, given the overlap between Form DQ and other reports. If the programme chooses to makes this report clearer, it needs to understand what the impact would be on other reports.
- EM clarified that this solution would go through a beta test first, to understand the consequences. The programme would want to implement this in a considered way.
- Members asked that the recommendations have precise wording, to make clear whether there are policy changes, and to make agreement easier.
- AD suggested that a deep dive session dedicated to the Form DQ recommendations for data standards would be useful. This would give clarity on the recommendations.
- Members confirmed that they would find this useful.
Action – Secretariat to arrange deep dive session for the committee with the Form DQ delivery team to go through the draft recommendations.
Update on CRE solutions work
The CRE delivery team presented an update on their solutions work, with particular focus on their principal solution of a new integrated strategic data collection.
The workstream has identified solutions in four areas. For some of these, the team has a proposed target state and they are trying to validate its feasibility. With the project now reaching the nine-month mark, the team is becoming smaller as some people return to their firms and so the team will need to prioritise its workload.
Transforming CRE data is dependent on designing a new strategic data collection. The Bank currently has multiple, inconsistent collections for CRE. While this may be presently sufficient, this is not future-proofed for risks such as climate change. Additionally, the Bank had identified a need to make the CRE Underwriting Return rules-based but had delayed this for TDC. The Bank cannot collect the Underwriting Return again until TDC reaches clarity on its future.
The team has now identified an interim and target state for CRE data collection. In the interim, it proposes that the Bank introduce a collection for regulated firms, re-establishing a regular collection. Its target state would then be an integrated collection, with a flexible data model and more complete market coverage (which may involve changes to the Bank’s available powers). The delivery team is currently working on the various design considerations of the interim and target state, including a list of data elements.
The delivery team presented an update on their work on data standardisation including a data dictionary. This will allow the BOE to collect an integrated data collection without causing additional burden. The team proposes to tidy up the Bank’s overlapping CRE data items through creating a business glossary and building this into a data model.
The delivery team presented an update on a solution involving the use of customer identifiers in CRE lending, in order to create a single customer view. This has three main options – mandating the LEI for all lending, mandating the LEI for material loans and allowing the use of alternative identifiers to achieve greater coverage.
Update on response to vendor demos
In response to previous inquiries from the committee, AS explained how the programme had engaged with vendors so far, particularly in the area of data standards. The programme had invited technology vendors to a workshop early in the programme to get their views on the problems with data collection.
In December 2021, the programme had published the problem statements that had emerged from the discovery work, and requested that vendors submit proposals on how theoretically to solve them. Around 30 vendors submitted proposals and the programme then selected a group of around half of these to give detailed demonstrations in January 2022. The programme team then assessed these demonstrations for their suitability for the use case in question, potential wider applicability etc. This exercise provided valuable learning for the delivery team.
Since then the programme has not acted on any of the vendor proposals, as these are still theoretical. After the committees make their recommendations, the regulators will consider whether to implement any of the recommended solutions and whether any technology vendors would need to be part of the solution.
Committee members also discussed their own preferences regarding how the programme should make use of solutions from technology vendors.
Recruitment for Phase 2
AM explained the programme’s resource need for Phase 2. Some people will leave delivery teams at the end of Phase 1 and the programme needs to replace them and further expand. The programme’s key resource needs are people for the discovery and design work (including design leads and developers) as well as further staff for scaling work.
The governance committees will remain constituted during Phase 2 and the DSC members are all encouraged to continue participating.
Selection of Phase 2 use cases
AM presented the Bank and FCA’s chosen use cases that they intend to pursue for Phase 2 of the programme, subject to confirmation of resources. The programme will take forward five use cases into Phase 2 – the S.06 Assets report for Solvency II insurance firms; Incident and Outsourcing & Third Party reporting; Retail Banking Business Model Data, a review of prudential data collections from FCA solo-regulated firms, and CRE data.
The programme has decided to extend work on the existing CRE data use case into Phase 2 in order to allow for completion at the right level of depth.
CC further explained that while ESG was a popular choice, the FCA’s relevant specialists would be busy for the near future with other work such as disclosure requirements. The programme will therefore not work on ESG this year but may do so in future.
Forward agenda / AOB
AS recapped the next steps, namely that the delivery team would draft some formal recommendations documentation and circulate this to the committee in the coming weeks. The Secretariat would consider appropriate times for Committee meetings in the coming months.
In other business, AD mentioned that he and a group of committee members were preparing to write a letter (in their own name) to Companies House, to give their view (previously expressed in the Committee) that there would be benefit from Companies House issuing LEIs.
Action – delivery team and Secretariat to circulate recommendations documents to the Committee.
Matthew Ash (MA), Barclays
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
Rob Dunse (RD), Lloyds Banking Group
Lee Fulmer (LF), UBS
Sharon Howells (SH), NatWest (TDC Project Manager)
Milind Joshi (MJ), Barclays
Elizabeth Maloney (EM), JP Morgan (TDC Project Manager)
Angus Moir (AM), Bank of England (Transformation Programme Lead)
Emma Price (EP), Santander Group
Aaron Shiret (AS), Bank of England (TDC Secretariat)
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 (External Engagement Lead)
Ian Wilson (IW), Nationwide Building Society
Richard Young (RY), Bloomberg
Julian Batt, Bank of America
Dave Holland, Coventry Building Society