Date of meeting: 16 February 2023 | Location: Bank of England / Microsoft teams meeting
Data Standards Committee
Item 1. Introduction
AD introduced the meeting and ran through the meeting agenda. AS recapped the actions from the previous meeting and asked the committee to approve the minutes.
Members had no comments and approved the minutes from the November meeting.
Item 2. Data Standards Review
AD explained the progress of the Data Standards Review, explaining that he and colleagues had a meeting with EY earlier in the week to pass on committee feedback on the draft report. The committee had provided suggestions for extra analysis in the report that would be useful to readers and EY had committed to provide additional analysis.
A key section of the final report would be a series of conclusions, which could then help the DSC to make recommendations off the back of the report.
With regards to the report’s purpose, LD explained that the regulators see data standards as very important for TDC and that the report’s findings can help develop a proof of concept for further work. AD hoped for the report to result in a period of informal consultation about data standards and a formal response from regulators.
JB spoke of the difficulty in quantifying the benefits of different data standards. LD explained that level of adoption can be seen as a measure of benefit. On the question of the role of regulators (a question considered by the report), committee members had differing views on whether large scale adoption driven by regulatory mandate should be considered a success.
Action: Secretariat to circulate EY’s plan for finalising the report.
Item 3. Phase 2 use cases – updates and discussion
AS reminded the group of the Phase 2 use cases: Commercial Real Estate (CRE), the FCA’s Strategic Review of Prudential Data Collections; Retail Banking Business Model data (RBBM); and Incident and OATP Reporting (IOREP).
Commercial Real Estate
MT presented the progress made so far on the CRE use case. The team is building on the work in TDC Phase 1 but has improved the approach for work during phase 2, which now benefits from a dedicated product owner and a clearer scope.
The use case team has developed granular problem statements, both from the perspective of firms and the Bank. The team has then aggregated these into a set of statements capturing recurring themes. On the firm side these include unclear expectations and disalignment between requirements and firms’ own practices. On the Bank side, they include disalignment between datasets and incomplete coverage. MT explained that the team had started work on prioritising the problem statements and that the next steps will be a series of design workshops with SMEs to begin work on designing a new end-to-end process.
Key discussion points:
- JB asked about the volume of data already collected. MT explained that they had looked at five main BoE collections: STDF, COREP, FINREP, Loan book data and the CRE Underwriting Review. Combined, all of these reports look at >1000 firms.
- MT spoke about the higher execution risk with ad-hoc data collections, and that making collections more regular would reduce the negative impact of such collections. He emphasised that although setting up the framework for regular collections will have a high up-front cost, over time it should be cheaper for firms than ad-hoc collections.
Action: CRE team to circulate prioritised problem statements for comment and invite members to any relevant lab sessions.
MR (delivery manager for IOREP and CRE) gave an overview of the use case. He explained that the team will use consultants to deliver this work, which will last from late February until July.
Key discussion points / comments:
- Members emphasised the importance of this work as this data is requested by regulators globally. DH said he felt that the key deliverable for this use case will be a harmonised global standard. LD added that this is a unique use case examining policy and data collection at the same time which may mean it takes longer. She agreed that the international angle is important.
- Members questioned the logic of grouping together incident reporting and outsourcing reporting. MR clarified that the incidents this referred to are operational incidents and that discovery work could consider any overlaps or differences.
- RY asked how the committee would input into this use case. AS explained that the programme was planning a full committee meeting in mid-March, as well as committee workshops a few weeks after this. MR explained that consultants may reach out to firms individually to be involved.
Strategic Review of Prudential Data Collections
CC recapped the scope of the use case, which will place less focus on data standards. The team has completed most of its discovery work; CC gave an overview of the user insights gathered from internal and external users. The alpha phase will begin once discovery artefacts are complete.
Key discussion points / comments:
- DH emphasised the importance of a rigorous cost-benefit analysis before implementing any big changes due to the high cost for firms. LD explained that in the alpha phase the team won’t be making live changes to the systems so that costs and impact can be measured.
- DH explained that some smaller firms don’t have specialists who can work on this type of reporting so there may be some education required for those firms. LD added that some of the recommendations from phase 1 may help improve this via improved reporting instructions, better user experience etc.
Retail Banking Business Model data
CC gave an overview of the RBBM use case. He explained that the discovery phase had started, with user research about to begin. He explained that this dataset is important data for the FCA but currently expensive for firms to collect and inefficient for the FCA to analyse. There is also room to research data standards relating to the collected data as accounting standards are mentioned in the template.
Action: Committee members to contact FCA if they have interest in the Retail Banking Business Models use case.
Item 4. Update on Phase 1 implementation
DF explained that work on implementing the recommendations for Form DQ is in progress:
- For ‘better reporting landing pages’ and ‘restructured reporting instructions’, the Bank has developed prototypes for new webpages and content and recruited users for research. The team has begun using Google analytics data to understand web page usage.
- For’ counterparty classification standardisation’ prototypes have been reviewed and technical teach-ins organised for working groups. The start was delayed slightly due to resource issues but is still on track to deliver by July 2023.
Key discussion points / comments:
- GC asked about the rationale for moving from reporting in XML to XBRL. DF explained that it is a more structured way of asking for data, with embedded definitions.
CC gave an overview of the progress on the FRS (Financial Resilience Survey) recommendations. The FCA has made progress against all the recommendations, including rolling out a new intuitive form design for Consumer Credit Form 007 and consulting on a future version of the Financial Resilience Survey.
Item 5. Forward agenda / AOB
AS explained that the next meeting of the DSC is scheduled for 16th March 2023 and that workshops would be scheduled likely for the end of March. LD added that there is a townhall meeting scheduled for the 29th March at the FCA and encouraged committee members to attend.
Julian Batt (JB), Bank of America
Chris Caldwell (CC), Financial Conduct Authority (Data Collections Technical Specialist)
Gabriel Callsen (GC), International Capital Market Association
Lauren Dixon (LD), Financial Conduct Authority (Senior Manager, Data Collections)
Andrew Douglas (AD), Depository Trust & Clearing Corporation (committee chair)
Dayo Forster (DF), Bank of England (Scaling)
Dawd Haque (DH), Deutsche Bank
Jane Laughton (JL), Bank of England (Senior Change Manager)
Angela Pearce (AP), Pension Insurance Corporation
Corinne Powley (CP), Phoenix Group
Peter Royle (PR), Financial Conduct Authority
Olivia Selbie (OS), Financial Conduct Authority (Programme Manager)
Aaron Shiret (AS), Bank of England (TDC Secretariat)
Nicola Sincock (NS), Santander
Matthew Thompson (MT), Bank of England (CRE Product Owner)
Rebecca Whitwam (RW), Bank of England (TDC Secretariat)
Richard Young (RY), Bloomberg
Claire Thompson, Legal and General
Andrew Turvey, Belmont Green
Tom Jenkins, HSBC