A UK Based Tier 1 bank (a designated G-SIB) needed help to document key parts of it’s Metric Aggregation and Risk Reporting processes to comply with the Principles of BCBS239 (principle 1, paragraph 29).

The GFT team were allocated a range of businesses and portfolios to model: Investment Banking Credit and Market Risk, UK Retail, and Cards portfolios in UK, Europe and US.

  • The processes were captured in a standard structure using an Enterprise Class process modelling tool.
  • The client also required an assessment of the process compliance against the Metrics Aggregation and Risk Reporting Principles
  • A programme of projects to remediate potential gaps was already in flight – the GFT team assessed the fit of these projects to the process gaps in order to identify the route to full compliance.
  • A team of up to 15 FTE were rapidly deployed showcasing the full range of Business Consulting and Programme Governance capabilities – Risk SMEs, process modelling analysis, business consulting skills across Investment and Retail banking domains.
  • A defined set of regulatory and top risk management reports were decomposed to understand the metrics contained in each of the reports, by business unit and geography. Metrics were grouped and analysed against the firms’ Risk Management Framework.
  • Initial client work to translate the BCBS239 Principles into assessable requirements was completed for each ‘in-scope’ risk type.
  • The team worked with Business Unit IT and data processing experts, to understand the original source of each key risk indicator (KRI) to the first record, together with the metric journey through the infrastructure to  reports, including data lineage analysis.
  • Risk reporting processes from source to report were modelled and documented with approximately 20 attributes and gaps agreed with business and reporting teams.
  • Gaps were documented and assessed by severity, and aligned to the programme of remediation projects.
  • Specific remediation plans were negotiated with project managers, including scope and timescales to provide the clients with a roadmap to compliance.
  • The team completed the process modelling and gap analysis on time and on budget.
  • The mapping of gaps to potential remediation projects was an early deliverable, allowing the client to plan for remediating gaps not already aligned to a project.
  • The team played a key part in managing the overall programme – leveraging a deep understanding of the regulation, Risk metrics and reporting expertise, plus the industry position on compliance.
  • Having achieved ‘trusted partner’ status, their work is continuing though the remediation programme to drive out business requirements and monitor the progress of delivery towards the January 2016 compliance deadline.