AS introduced the meeting, explaining that it was the first DSC meeting of Phase 2. He explained the agenda, and that the meeting would be slightly different to normal, covering the Data Standards Review, and introducing new members and new use cases. The members of the committee all introduced themselves. 10 participants from Phase 1 have renominated themselves, with 7 new members joining for Phase 2.
DSC Terms of Reference
AS presented a reminder of the committee’s Terms of Reference. As part of the programme’s work to transform data collection, the Data Standards Committee serves as a forum to propose solutions in the area of data standards. During Phase 2, the committee will work with the delivery groups to understand the problems identified in the use cases, before reviewing their proposed solutions. The committee’s ultimate goal for the end of Phase 2 is to publish recommendations to regulators and industry in the area of data standardisation.
DSC engagement in Phase 2 of TDC
In response to feedback from the committee, and in line with the Secretariat’s thinking for how best to organise the programme, AS presented options for how the committee could interact with the design work.
In Phase 1 of TDC, the governance committees had a regular schedule of approximately monthly meetings, conducted on a formal basis. Towards the end of the phase there were some more informal workshops with the delivery groups to discuss solution prototypes, and the committees had asked for more of these sorts of session, in order to have a closer working relationship. The Secretariat proposed that in Phase 2 it could make use of a mix of formal committee meetings, ‘show and tell’ sessions where the delivery groups would present their work, and workshops of a more discursive nature to talk through specific solutions in detail.
The committee asked to have a mix of sessions, and to hold time in the diary for approximately every two weeks in order to allocate time. AS agreed that the Secretariat would arrange for a mix of sessions, and consider whether it would be possible to arrange fortnightly sessions.
Action: Secretariat to plan forward agenda including a mix of formal meetings and workshops / ‘show and tell’ sessions. Committee preference is for a hold in the diary every two weeks.
Data Standards Review update
MT presented to the committee about the review of data standards in financial services, including work performed and topics of discussion. The committee commissioned this work during Phase 1, and the review began in late September 2022. The EY review consists of four main activities – interviews with selected data standards specialists (including members of the committee), an online discussion board, desk-based research and consultation with the firm’s in-house experts. The online consultation was ongoing at this time and MT encouraged committee members to participate.
In interviews with specialists, topics discussed included the issues that standards can resolve and past examples of this, how to support implementation of standards, the role of regulators in standards adoption and the lifecycle of a standard.
Themes that have emerged from the interviews and online discussion are widely held perceptions of the benefits of standards, split views on the roles of regulators and the importance of creating processes for the maintenance of standards after their development. The most contentious area is the role of regulators – some in the industry feel that regulators should maintain and enforce standards, while others think regulators should just be leading a discussion with industry. Industry was unanimous however in its view that some form of industry committee on standards is necessary.
Comments had also emerged about the importance of certain key principles, such as interoperability – the ability to use standards for different purposes, and ensuring utilisation of existing standards rather than duplicating these efforts.
The final report will be presented to the committee for their consideration. The programme plans to publish the final version of the report.
The committee gave some reflections on issues raised by the review.
- DH explained his perspective, that he was against imposition of standards by regulators – he said all standards he had seen had been imposed in a top-down way, but that this will never work in financial services.
- AD thought that top-down methods of developing standards do not work, while bottom-up methods of implementing them similarly fail. He argued standards need the industry expertise in order to be developed, but then the regulator’s ‘stick’ to implement them, citing the example of the LEI, where mandating it in EU regulation drove adoption.
- Members spoke of the need to identify and learn from successful / unsuccessful standards initiatives, and to establish some basic tenets of what a good standard is, in order to facilitate future progress.
- MZ also spoke on the specific example of sustainability reporting, suggesting that the lack of a convening mechanism for standards for this is creating chaos for this area. He suggested that there would need to be some governance around such reporting, and that there isn’t the time to wait for a lengthy establishment process has happened with IFRS and GAAP.
Phase 2 use cases
AS introduced the phase two use cases and explained that two of the use cases (Commercial Real Estate and the FCA Strategic Review of Prudential Data Collections) are in progress with the other two (Incident and Outsourcing and Third-Party Reporting and Retail Banking Business Model Data) due to begin in early 2023.
LC explained the approach to the programme, which is following the government digital service approach. Work starts with a ‘discovery’ phase of research to fully understand the ‘as-is’ process and any current issues, before focusing in on defining problems and then moving on to developing solutions. She explained that the design approach would be user-centric, with rapid delivery and rapid replanning where needed.
LC went on to give an overview of the FCA Strategic Review of Prudential Data Collections from Solo-Regulated Firms (SRPDC). This use case aims to make it easier for financial firms to meet FCA prudential reporting requirements. She explained the use case is currently in the discovery phase and the team is conducting user research to understand the needs and pain points of users.
AS gave an overview of the Commercial Real Estate (CRE) use case, which is being continued from phase 1. He explained that the use case’s aims, which include ensuring the Bank has timely accurate and actionable data on CRE and eliminating redundant data fields and reports. The use case is currently in the discovery phase, which will run until the end of January 2023.
DPO gave an overview of the Incident and Outsourcing and Third-Party Reporting (IOREP) use case which is part of a public commitment from supervisory authorities to develop joint incident and OATP reporting policies. He explained that the use case is projected to start discovery in February 2023 with the aims of improving data quality whilst reducing the resource and time needed to collect it.
CC gave an overview of the Retail Banking Business Models Data Collection (RBBMD) use case. This looks at a dataset collected on an ad-hoc basis which had the original purpose of studying the retail banking market from a competition perspective. He explained that the discovery phase is due to start in January 2023.
Update on implementation of phase 1 recommendations
DF gave an update on the implementation of phase 1 recommendations for the Form DQ use case:
- The Bank of England has committed to delivering valuable change by June 2023 and is on track for delivery of the three recommendations (better reporting landing pages, restructured reporting instructions and counterparty classification standardisation) by June 2023.
- Work is underway aligning the delivery of the recommendations with internal work streams in the Bank – data collection hub, data inventory and ad-hoc collections.
- The team is filling roles to increase data, regulatory and service design skills and is developing their implementation approach.
Forward agenda / AOB
- AS reminded the group that the consultation element of the Data Standards Review was still open and encouraged them to take part.
- The Data Standards Review would be on the agenda for future meetings (and would form the focus of a future meeting early in 2023). The Secretariat would circulate the report to the committee for their review once received.
- Early in 2023 there would be workshop / show and tell sessions with the use case teams for CRE and SRPDC.
- The Secretariat planned to organise the next full committee meeting for February. The committee asked that there would be some engagement before then, particularly on the Data Standards Review.
Action: Secretariat to circulate draft Data Standards Review report to the committee when available.
Action: Secretariat to set up workshop sessions for early 2023 on CRE and SRPDC, and to discuss the DSR.
Actions agreed in this meeting
- Secretariat to arrange mix of session formats during Phase 2, including workshops with delivery groups.
- Secretariat to arrange committee meeting to discuss Data Standards Review report and arrange for multiple rounds of review.
Ffion Acland (FA), Goldman Sachs
Julian Batt (JB), Bank of America
Naomi Beckett (NB), UBS
Chris Caldwell (CC), Financial Conduct Authority (‘FCA’) (Data Collection Technical Specialist)
Laura Cusack (LC), Financial Conduct Authority (Delivery Manager)
Lauren Dixon (LD), Financial Conduct Authority (Senior Manager, Data Collection)
Andrew Douglas (AD), DTCC (DSC Chair)
Maria Esteban Casadevall (MEC), EY
Dayo Forster (DF), Bank of England (Scaling)
Dawd Haque (DH), Deutsche Bank
Tom Jenkins (TJ), HSBC
Angus Moir (AM), Bank of England (Transformation Lead)
Destiny Patrick-Ogbu (DPO), Bank of England (IOREP Delivery)
Angela Pearce (AP), PIC
Corinne Powley (CP), Phoenix Group
Olivia Selbie (OS), Financial Conduct Authority (Programme Manager)
Aaron Shiret (AS), Bank of England (TDC Secretariat)
Nicola Sincock (NS), Santander
Tammy Solomon (TS), Investec
Claire Thompson (CT), Lloyds Banking Group
Andrew Turvey (AT), Belmont Green
Matthew Tyrrell (MT), EY
Brian Weber (BW), JP Morgan
Rebecca Whitwam (RW), Bank of England (TDC Secretariat)
Richard Young (RY), Bloomberg
Mike Zehetmayr (MZ), EY
Gabriel Callsen, International Capital Markets Association