IFRS 9 Control Framework

The customer is a retail belgian bank focusing on mortgage loans and consumer credit. Following the implementation of the IFRS 9 ECL calculator, the need arised to implement a control framework to ensure timely and quality calculation and bookings, and integration in the accounting and reporting platforms. Avantage Reply helped the client bridge the distance between different departments to identify the right responsibilities at the right moment in the process to increase its reliability.

CUSTOMERS GOALS

The objective of the project was to :

1. Set up controls on the IFRS 9 process : especially on the input part, a shared paltform for Risk, ALM and accounting under the principle of One Data Source.
2. Embed the controls in the organisation of Bpost Bank, including process desctiption, the definition of roles, Raci matrixes and a management cockpit.
3. Leverage on the previous work perfomed on the models by another firm, the recommendations of the auditors, and of the regulators

THE CHALLENGE

The first big issue was an organizational one: defining responsibilities for data that are received from an external provider, and that are re-used and shared across different departments. The two other main issues were linked to the project: the control framework was to be set up on a “TO BE” architecture, including changes linked to the new definition of default project that were not stabilized yet, making for a “moving target” situation. Finally, the project was delivered in the context of the Covid-19 lockdown, which limited our access to client network and resources.

APPROACH AND SOLUTION

The solution proposed by Reply was in three phases:

1. Collection of the controls, quality criteria and common pitfalls
2. Control framework definition, quality assurance
3. Implementation and roll-out, embedding in the existing tools

CUSTOMER DESCRIPTION

The customer is a retail belgian bank focusing on mortgage loans and consumer credit.It serves over half a million clients. Our customer offers the various services of a traditional bank: the banking account, savings books, consumer loans, mortgage loans and credit insurance.