Date of meeting: 1 March 2022
Location: This meeting took place via Microsoft teams
Actions agreed in this meeting
- Secretariat to invite committee members to working groups with delivery teams.
AS welcomed all to the meeting. The Committee confirmed its approval of the minutes from February. AS recapped the actions from the February meeting and gave updates on these.
- Currently Bank of England colleagues working on the LEI are focused on the actions within the Bank’s remit that it could take to increase use of the LEI, rather than considering whether changes to the role of Companies House would be beneficial to the Bank’s objectives, as the Bank has less influence over this.
- The Secretariat will add an item to a future DSC agenda to discuss further the topic of mandating the LEI.
- The programme plans further workshops between the delivery groups and members of the committees, to discuss solution design. The Secretariat will invite volunteers to these groups. In addition, when setting the agenda for these meetings the programme will consider the extent of decision making to delegate to the working groups.
Action: Secretariat to invite committee members to working groups with delivery teams.
Project plan update
AB presented a progress update. Use case workstreams are well into the Alpha phase and solutions are in varying stages of peer review and testing, with CRE proving most complex.
AB then gave an overview of the project plan. With the exception of CRE, the programme is looking to finalise the Phase 1 recommendations around the end of March. Regulators will then spend Q2 deciding how to respond to these and will consult on implementation later in the year as appropriate. Additionally we are working on the development of ‘standards as a service’ – the Bank’s standardisation efforts forming an ongoing service to the industry, with the Bank working to develop and maintain standards. The Data Standards Review we are commissioning will support this effort.
Cross-use-case solution – Data Dictionary
AB introduced a discussion, returning to the topic of a data dictionary. The programme has repeatedly identified the need for common meaning in relation to data attributes. A dictionary would provide an accessible place to find definitions that work for different users.
AB presented the delivery teams’ high-level proposal – to build a data dictionary for attributes from Form DQ, CRE data collections and the Financial Resilience Survey. The team proposes that the dictionary would include all 25 attributes for Form DQ, as well as three key attributes for CRE data collections and 8 attributes for the FRS. This would focus on business glossary definitions (rather than legal or technical definitions). He also explained design principles that would guide this, like meeting user needs, simplicity, transparency etc.
TS asked why only three attributes were under consideration for CRE. AB clarified that at this stage, the focus was on three attributes, but as the workstream progressed this would expand.
The committee then discussed how to approach development of the utility, expectations for regulators’ role in ongoing maintenance of it, and the value and risks that might result from scaling it across use cases. To guide the discussion AD asked the committee to comment on the dictionary’s purpose, necessary governance arrangements and funding considerations.
Key discussion points / comments:
- Members agreed that the governance of the dictionary would need to involve both regulators and firms, as firms would raise issues to regulators.
- Members spoke of the need to establish definitions in a big initial implementation, but then allow these to remain in place – firms do not want definitions for data items to change after they have set them up. If regulators then want a data item with a different definition, they should set up a new field (with a different name), so that they are establishing a different concept rather than re-defining the same one.
- Some members felt that the content of the data dictionary itself was the prerogative of regulators, as they are collecting the data, but felt that non-binding guidance similar to the EBA’s Q&A processes would be a helpful addition.
- Members suggested that the UK try to align to international standards where possible. DH cited the example of IOSCO’s Critical Data Elements dictionary, suggesting the UK should adopt the parts of this that it likes.
- AD proposed that when defining attributes in a UK dictionary we should first consider whether they are defined internationally, in order to contribute to long-term convergence. DH agreed, but added that a certain amount of divergence can be a good thing, citing the EMIR refit that he felt was beneficial for the UK industry.
- AT mentioned that he thought a risk for firms was the regulatory expectation around compliance with the dictionary. He felt there should be clear guidance explaining what firms should do to align, including timelines for implementation and materiality thresholds for the extent of their compliance.
- Members mentioned that some fields appear on multiple reports but with diverging definitions, sometimes for no strong reason. A data dictionary could help to smooth out those differences – so long as it did more than just take this existing approach and put it into a new format. Members wanted to align definitions.
- IS added that these definitional differences are often of little benefit as when analysed, the different items they create display little difference from each other (but create extra work). He suggested for a derivative only around 20 data points are necessary.
- AD asked the group whether the operating model for the dictionary needed to involve industry associations (rather than institutions individually). Some members felt this would be beneficial as such bodies would have an industry-wide view, while others felt that industry bodies had a bias towards expanding existing approaches.
Form DQ solution – data attribute standardisation / amended instructions
EM presented a solution emerging from the Form DQ workstream. The delivery team has identified the ambiguity of instructions and a lack of standardisation as problems. She demonstrated the BOE webpage for statistical reporting; preparing a report involves reading several long documents in PDF form, with relevant information spread across all of these.
JG then explained the solution the delivery teams had developed for this. He had looked at the Form DQ information from the perspective of the user in a firm preparing the report. He explained that reporting instructions tend to be written from the perspective of the data recipient, while the preparer typically needs more granular information than this.
JG presented the prototype solution he had developed. This involves splitting the instructions information into one document for the ‘real’ instructions and another that gives data definitions- a data dictionary. In spreadsheet form, the dictionary captures each attribute, gives definitions for these, sources for the definitions and suggested data standards that should apply in those definitions e.g. an ISO standard.
In some cases the prototype suggests moving from an existing standard to a different one, if this is more likely to achieve the report’s intended outcome, which is to provide statistics required by the ONS. For example, the prototype suggests moving from using the BOE’s Classification of Accounts guide to ESA 2010 for some attributes, for this reason. It also suggests that the version of SNA coming in 2025 might be a useful standard.
The group then gave their thoughts on the prototype, and the principle of applying specific international standards in the data definitions.
Key discussion points / comments:
- RY sought to clarify the ultimate goal of the proposal e.g. several similar dictionaries for specific use cases. AD confirmed that the intention was to build out this utility repeatedly.
- Members agreed the importance of aligning definitions across use cases. Either one definition of an attribute should apply across multiple reports, or if a different definition needs to apply somewhere, it should form a different attribute entirely.
- EM cited the example from Form DQ of industrial classifications that would be widely applicable in this way.
- Some members were concerned about aligning definitions and then applying these retrospectively towards historic collections. Other members thought that this was not a concern, as the alignment of definitions would not reveal that firms had previously reported in error, but reveal that previously there were multiple acceptable interpretations, which would now converge to one definition.
- DH asked that firms receive sufficient time to implement such solutions, referring to recent regulatory changes where regulators have only given 6 to 12 months to implement, failing to consider the impact on firms.
- AD asked the group whether they thought regulators should mandate use of the dictionary, or whether further cost-benefit analysis was necessary. Some members thought that the investment might pay back (for comparison, research on the DRR project suggested the EMIR refit changes would pay back in 4-5 years). Other members wanted to first understand how much change this would involve for firms, suggesting that the programme speak directly to the Form DQ reporting population.
CRE use case update
SH presented an update on the CRE workstream. The programme has extended this workstream until the end of May due to the complexity of the solution design work. SH gave updates on the solutions relevant to DSC’s work – CRE data dictionary, the use of customer identifiers and a guidance tool for standardising deal capture.
Work on the latter solution has been paused due to resource constraints. The work on the dictionary and identifiers is ongoing, with working groups planned for March. SH encouraged committee members to volunteer for these working groups to provide input on the solutions.
Phase 2 use cases
AM presented the long list of eight potential use cases for Phase 2 of the programme – five BOE use cases and three belonging to the FCA. The programme team is currently assessing which of these to take forward. He explained that the Reporting Transformation Committee had voted on their preferences, which the programme would weigh up against feedback from DSC, regulators’ internal preferences and constraints.
DH thought the FX reporting use case was useful but that there had been large standardisation in this area already. He supported the Incident and Third Party Reporting and ESG use cases, noting that the former was an existing form of reporting, while the latter is a new area without implemented requirements, in which the industry is very actively working. He suggested that pursuing ESG could deliver a lot of positive change, while having a lower level of disruption.
FA also supported the ESG use case, as this would likely impact all the other use cases indirectly. She also cited Liquidity Metrics Monitoring as an area where other regulators are active and so this could be a way of coming to a more holistic solution for liquidity. RY supported the ESG use case, mentioning that there were efforts to develop taxonomies both in the UK and the EU. ISO are also working in this space.
Forward agenda / AOB
AS presented the group’s forward agenda, with the next meeting scheduled for the end of March. The next meeting of the Board is also coming in mid-March. The remaining Phase 1 meetings would consider the investment case for proposed solutions, make final recommendations and consider planning for implementation of recommended solutions.
Ffion Acland (FA), Goldman Sachs
Miles Barker (MB), Credit Suisse
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
Joel Gillow (JG), UBS
Dawd Haque (DH1), Deutsche Bank
Sharon Howells (SH), NatWest (TDC Project Manager)
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
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)
Richard Young (RY), Bloomberg
Dave Holland, Coventry Building Society