Addressing CCAR MRAs: 6 Data Governance Capabilities You Need (but may not have)
As banks continue to work diligently to build sustainable data governance for CCAR, many of them are finding that a mind shift is required. It’s no longer sufficient to think in terms of data management. For banks to ensure that they can efficiently sustain regulatory compliance now and in the future, they need to shift their thinking to focus on data governance. And this shift in thinking requires a different set of capabilities than the ones they likely have in place today.
Many other vendors on the market today provide sets of capabilities that help you manage your data. But they provide these capabilities piecemeal. Some provide a data glossary, data lineage and traceability, reference data, and master data management capabilities. Others may deliver the ability to manage critical data elements, metadata, and data quality testing. And still others focus on data dictionaries, controls, and report catalogs. These solutions do provide value in their own right. But they usually aren’t user-friendly. And they don’t connect to each other. Data lineage is separate from metadata. Data quality results don’t connect to the data dictionary. The processes are separate and impossible for data stewards to manage effectively. And on top of all that, many of these tools are built with technical users in mind. They are not designed to be easy for the business data steward to use. To truly get ahead of regulatory compliance – and to have a sustainable process in place – you need more.
The best data governance platforms provide all of these capabilities together in one easy-to-use, comprehensive solution. They can connect to your other systems in an automated and integrated way. They enable you to replace your Excel, Sharepoint, and meeting-intensive processes with ones that are automated, so you can focus your meetings on the most important decisions at hand. And they connect your business users to the data in a way that is usable.
So how do you know if your data governance platform checks all the boxes? We’ve created a simple checklist of six must-haves for you to review.
1. CCAR Reporting: every CCAR bank needs this one
The best data governance platforms deliver the FRB’s FR Y 14 M/Q/A and FR Y 9C schedule and data points definitions. They also help you identify CDE’s and link to the report line numbers/MDMs for the appropriate CCAR report.
2. Dashboards & Reporting: get rid of the status reporting nightmare
Make sure you have the ability to visualize a heat map dashboard of your CCAR data governance status (the regulators will ask!). You’ll also want the ability to monitor progress of CDE governance (including data lineage, data quality, and data ownership) as well as trend reporting for issue management, MR(I)As, and data quality.
3. Operating Model: a real a game changer
True data governance platforms provide defined governance roles and responsibilities with attestation workflows and reporting. They integrate data governance processes across your existing data management tools, and deliver process flows tied to working groups by domain/schedule/data elements with automated workflows.
4. Data Quality: another top priority as you address CCAR data governance challenges
Look for data governance platforms that incorporate Fed edit checks with other data quality results to track the status of fed edit checks and issue management reporting. You’ll also want comprehensive business rules so you can track quality scoring of business rules and manage on-boarding of new business rules through automated voting and approval workflows.
5. Data Lineage: the hottest topic in the data governance world
Make sure you can maintain business and technical lineage, including key controls. You’ll also need the ability to track – and automatically maintain – data lineage from source to target, manual intervention points, transformation logic, and more.
6. Issue Management: make it easy to fix what’s broken
Look for solutions that help you initiate workflows and monitor issue resolution for data governance and quality issues with automatic escalation including for MRAs.
Ask your data governance vendor if they provide all of these capabilities. Some will say yes – some may not. And others may say they provide these capabilities, when in fact, they don’t. To make sure you’re getting the right data governance solution for the job at hand, ask your vendor or potential vendor these five questions:
- How does your solution connect data management capabilities such as data lineage, metadata, data quality scores, and attestation with data governance requirements such as attestation, voting and approval, and data sharing agreements?
- How does your solution help data analysts find data they can trust?
- How are data governance roles and responsibilities and operating model combined with data management tools?
- How do you enable and automate process flows across data management tools and data governance processes?
- How do you link data management issues with your data governance operating model, roles, and responsibilities?
What are your must-haves for a data governance solution? Would you add anything to the list?
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.