The client is a European Private Bank with Wealth Management operations. In the context of the expected transition to direct supervision of the ECB (European Central Bank), the client has requested Avantage Reply to assist in undertaking an assessment of its Data Governance Framework and Data Quality to provide the bank with a set of practical recommendations to ensure that the bank can satisfy the requirements of the ECB in light of BCBS 239 (The Basel Committee on Banking Supervision’s principles for effective risk data aggregation and risk reporting).
The customer wanted to undertake an independent readiness assessment on their Data Governance Framework, roles and organization around data in scope when under direct ECB supervision. Additionally, the client aimed at aligning with the Group Data Governance standards and to comply with the BCBS 239 principles. Finally, a business case input for technology enhancements and hiring were requested.
In a short timeframe, the client requested a review of the Data Governance Framework and assessment of the data quality in light of ECB expectations. The regulatory requirements included BCBS 239, EBA Guidelines on Internal Governance (EBS-GL-2017-11), and CSSF Circular 12/552 on Central Administration, Internal Governance and Risk Management.
Also, the client requested a deep dive in important data points, which was a major challenge due to the diversity of data types and the number of contacts which needed to be interviewed. Additionally, the definition of roles and responsibilities turned out to be a significant challenge.
Avantage Reply reviewed the supporting documentation regarding Data Governance Framework and definitions of Roles and Responsibilities and conducted a gap analysis between status quo and ECB expectation in light of the regulatory environment as mentioned above. Based on this gap analysis, Avantage Reply provided a readiness assessment concerning the direct supervision by the ECB and the accompanied expectations. Also, practical recommendations were given to the client, including a strategic roadmap for the following year.
Additionally, a Data Quality Assessment for a subset of 60 data points was performed. This exercise led to a list of data quality issues and recommendations for remediation, including a categorization of the issues in light of urgency and impact.
Finally, Avanatge Reply organized a workshop with peers from the industry which experience direct supervision by the ECB, in which the client was able to receive direct feedback on the readiness of the institution and the requirements by the ECB.