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A New Approach to Addressing CCAR MRAs

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A New Approach to Managing CCAR MRAs

If you’re like many CCAR banks I work with, you recently received your CCAR feedback and are now frantically sorting out a response to the latest round of MRAs. And I suspect that what you’re finding is that you’re struggling with issues such as how to report status and progress, how to document data lineage, and how to establish and evaluate CCAR data controls. If this all sounds familiar, then don’t worry, you’re not alone.

But knowing you’re not alone doesn’t make the headache of the task of responding to MRAs any less painful. Couple that with the fact that the regulators have been hounding you and other CCAR banks about putting in place sustainable data governance, and the headache only grows. But as you think about how you’ll respond to the latest MRAs, as well as put in place a longer-term, more sustainable plan for compliance, I challenge you to think of solutions outside of the regulatory compliance box.

What if you used BCBS 239 principles as the basis for the data governance processes around CCAR data?

As I mentioned above, regulators have been pressuring you to put in place sustainable data governance practices.  And they are also increasingly pointing to the BCBS 239 principles as the basis for their requirements and expectations to assess CCAR reporting processes. So what if you brought the two together as part of your plan and response to your MRAs?  In addition to looking like a regulatory compliance rock star, you would also set your organization up for true, sustainable data governance.

Let’s look at how this would work in practice. If you think about the BCBS 239 principles, there are 5 primary principles:

  1. A well-defined data aggregation and reporting framework
  2. A data governance program identifying controls and accountability across the data lifecycle
  3. A data dictionary and definitions used consistently across the organization
  4. A robust data quality and reconciliation processes
  5. A simplified data architecture to enable more automated data and reporting processes

Using these principles as the foundation of your data governance program would help you to do a number of things, all of which support CCAR as well. First, you would use the same data governance language as the regulators – no interpretation required. Second, there’s the regulation trickle-down effect: regulators are using BCBS 239 to assess your CCAR reporting, and they are applying these principles to non-GSIB banks during reviews of other regulatory reporting. Third, it gives you an efficient, integrated approach to data governance across the CCAR data supply chain. And finally, it positions your bank to more readily adopt future internal and external reporting changes.

Now, you may be thinking that this all sounds good from a processes standpoint, but how would you support this from a systems and technology perspective? The answer is simple: Collibra.

Collibra is the data governance solution for CCAR. We deliver out-of-the-box operating models, based on BCBS 239 principles, that help your organization make data governance business as usual. Not only does Collibra help you address the immediate MRAs, but it also helps you reduce the herculean effort required to stand-up data governance for CCAR: report status, document data lineage, track issue accountability and resolution, and more. In short, it helps you to improve quality and make data governance sustainable and efficient.

Simon is the Collibra Global Financial Services Market Lead. During his 20+ years of management consulting services experience at leading consultancies EY and PwC, Simon helped financial services institutions design and implement information and data governance processes to support internal, external, and regulatory reporting including BCBS 239 and CCAR.