Date of meeting: 2 March 2022
Item 1 – Introduction
AS introduced the agenda. AS recapped the actions from the previous meeting (Secretariat to clarify role of the committees in implementation work). He noted that as the implementation work was yet to come, the Secretariat would clarify this nearer to the time.
The minutes from the February meeting were approved.
Item 2 – Project Plan
AB presented an update about the project status. He explained that testing work on most of the solutions is in progress, and that the programme is nearing the end of the first phase.
Given the scale of the CRE use case and the opportunity for transformation in that area, the programme has extended this workstream until May, which RTC has agreed.
Concerning solution scaling, the programme has created some draft design principles that should apply to data collections in future, to achieve a consistent approach in all areas.
The overall project status is ‘Amber’. In order to ensure the project gets back to ‘Green’ more resourcing and different capabilities are required, including business analysts, experts in service design, graphic designers etc.
Item 3 – Form DQ solution deep dive
EM and RM1 presented a solution from the Form DQ workstream, aimed at improving the communication of reporting requirements. The team has worked on improving user experience with the statistical reporting webpage, which is difficult to navigate, with large amounts of information, not all of which is very relevant. The team have designed a prototype for a new website for Form DQ requirements to solve this.
RM1 demonstrated the prototype. He showed that on the existing BOE webpage, searching for Form DQ brings many search results but there is no way of telling what is relevant. The prototype webpage would return a dedicated Form DQ webpage as the main search result. This will take users to the relevant information.
A new reorganised webpage houses the relevant information for Form DQ, including the core documents for report preparation in one table. This page also includes new explanatory copy outlining why the Bank needs to collect the data (for the ONS). RM1 explained his view that explaining the benefits of people’s work to them is important in motivating them.
RM1 also expressed his hope that the Bank could develop a chat function (involving a chatbot) so that firms could interact with the regulator at the level of data they require.
In the short term, the programme would look to develop a beta version of this webpage, alongside other Form DQ solutions for the reporting instructions. In the medium term, the programme would work on fixing broken links and building other features such as improved quality assurance around submission and building a live bot helpdesk.
The committee then discussed its views on this roadmap for transformation, and any additional things that they thought would build the case for investment.
Key discussion point /comments:
- AT suggested that the prudential and statistical arms of the BOE should work on a combined website in order to get synergies. He suggested that they could use an API to direct reporting queries appropriately. He asked when the BOE would be able to deliver the team’s medium-term recommendations.
- EM said that while delivering the short-term recommendations should not be problematic for the Bank, it was less clear when the medium-term recommendations could be delivered, but that future use cases would be able to pick up any solutions not delivered as part of Form DQ work.
- Members agreed that a chat-bot feature or a Q&A function would be very useful and they were keen for the Bank to deploy this more widely across use cases, citing a lack of communication from regulators about more detailed queries as a common problem. DF added that firms have admitted reticence about contacting regulators about such issues and that firms also want specific contacts rather than inboxes to raise queries.
Item 4 – Commercial Real Estate solutions
SH presented a summary of the CRE workstream solutions and an update on the workstream’s progress. She explained that the programme team had extended the workstream until the end of May. The CRE team has organised a workshop in the coming days to progress the design work on an integrated data collection for CRE data. Meanwhile the team proposed to pause the work on a guidance tool for deal capture as the relevant SME was unavailable and there is some dependence on the work on building a data dictionary. The Committee did not object to pausing this work.
Furthermore, SH explained how work on CRE during this phase has highlighted opportunities for scaling now being pursued. The integrated data collection solution shows the principles that we should follow for data collection. The data dictionary solution has shown the importance of looking across use cases to ensure that we can scale-up solutions. A proposed market analytics solution focuses on providing value to firms from the reporting process, not just regulators.
Finally, SH requested that committee members volunteer (or identify colleagues from their firms that could volunteer) for working group discussions on the different solutions in the coming days.
ACT: Secretariat to invite committee members to working group sessions and committee members to volunteer / invite further volunteers from their firm.
Item 5 – Financial Resilience Survey solutions
CC presented further solutions from the FRS workstream. The FCA proposes a new standardised form for submitting regulatory returns. This includes a number of help features and a ‘work mode’ where submitters can write things alongside their submission. This solution should provide a consistent user experience whenever firms provide data to the FCA.
AT remarked that this facility should result in better quality data, and that the FCA’s value statement should include this.
CC explained that the FCA intends to pause work on a tool for identifying data duplications. This work has a dependency on the metadata relating to the FRS report, which forms part of the data dictionary work. The work therefore cannot progress currently. The committee agreed that pausing the work was necessary.
CC presented a solution relating to the design of the FRS survey itself. The FCA has analysed data duplications and as a result plans to reduce the survey from ten questions (sent to 20,000 firms) to a set of five questions, while reducing the survey scope by 3.500 firms.
CC explained the template headings that the programme will use for explaining the investment case for the FRS solutions. He asked whether there were additional elements to consider. Members mentioned they would be keen to know about implementation timelines.
Item 6 – Scaling
DF presented an update on the work to scale-up solutions emerging from the programme. The programme aims to re-use solutions across use cases and tackle more complex problems. The programme has learnt a number of things from the priority use cases, such as the need to move away from unhelpful publication formats and explaining why firms need to report.
The project’s work on common data standards has shown that there is a path to improvement in this area. Solutions like counterparty classification mapping can be scaled across statistical reporting. Regarding integration of reporting, the project has highlighted that firms dislike facing repeated requests for similar data and that it would be better to ask for data at the level of aggregation regulators really need.
In the near future the programme will consult stakeholders and agree a roadmap for rolling out scaling. The programme will design a transformed data service for all statistical collections. In the April to June period, the programme will focus on transitioning to Phase 2.
Item 7 – Phase two use cases
CC presented an update on the selection of use cases for Phase 2 of the programme. The programme team is still in the process of forming a shortlist, but would reflect on comments from this meeting. He presented the results of a vote of RTC members, showing that asset reporting for insurers and liquidity metrics were among the most popular potential use cases from the longlist previously shown. Loan book data from non-systemic firms and incident and outsourcing reporting were among the least popular use cases among firms (though they are potentially beneficial use cases for regulators). CC and colleagues then presented some of the solutions to the group by way of explanation, including the above use cases and others.
Key discussion points/comments:
- Members remarked that they thought the loan book data use case might cover similar ground to the CRE use case and they preferred to diversify the use cases.
- PT thought that there was a theme among proposed use cases - of trying to automate manual, Excel-based processes. He spoke of the need to consider other potential benefits of use cases beyond automation.
- SL thought that environmental, social and governance information was a big area of development that would affect the whole industry, and therefore the programme should aim to work on that dataset from the outset in order to get that right.
- Regarding a potential use case around a strategic review of collections from solo-regulated firms, DS asked if this would take in insurance. CC confirmed that this would only apply to solo-regulated firms.
Item 8 – Forward agenda/AOB
AS presented the forward agenda for the remaining Phase 1 meetings, which would focus on the Phase 1 recommendations and investment case.
Actions agreed in this meeting
- TDC Secretariat to clarify the role of the committees in the delivery process.
- Secretariat to invite committee members to working group sessions and committee members to volunteer / invite further volunteers from their firm.
Andy Beale (AB), Bank of England (TDC Programme Manager)
Paul Burleton, BNY Mellon
Chris Caldwell (CC), Financial Conduct Authority (Transformation Programme Lead)
Jacqueline Davies (JD), TSB Bank
Dayo Forster (DF), Bank of England (Product Owner)
Sharon Howells (SH), NatWest (TDC Project Manager)
Sandy Leggeat (SL), Goldman Sachs
Elizabeth Maloney (EM), JP Morgan (TDC Project Manager)
Robert McBride (RM1), Lloyds Banking Group
Ruaidhri McInerney (RM2), Macquarie Group
Angus Moir (AM, chair), Bank of England (Transformation Programme Lead)
Derek Paine (DP), Mizuho International plc
Robert Pengelly (RP), Nationwide Building Society
Gemma Poddington (GP), Credit Suisse
Charles Resnick (CR), ClearBank
Daniel Sadler, Association of British Insurers
Aaron Shiret (AS2), Bank of England (TDC Secretariat / Data Standards)
Tammy Solomon (TS), Investec
Robert Thickett (RT), Building Societies Association
Paul Thirtle (PT), NatWest
Andrew Turvey (AT), Belmont Green
Martin Udy (MU), Bank of England (TDC External Engagement Lead)
Richard Walker-Smith (RWS), Bank of America
Pardeep Bhatti, Metro Bank
David Palmer-Lewis, Principality Building Society