BCBS 239: Overcoming Ownership, Literacy & Change Fatigue

12 years, 11 principles, 10 regulatory reports and thematic reviews and 7 key expectations. Implementing BCBS 239 was always going to involve a steep learning curve. We’ve distilled the regulatory chronicles into 3 themes banks must get right - Culture, Execution and Infrastructure. 

Let’s start by unpacking Culture. 

Ownership: The most persistent challenge (and the first of seven expectations in the ECB’s 2024 review) revolves around effective management and oversight. Spreading ownership across Risk, Technology, Data, and Business teams leads to stagnation and diluted focus. Yet, no single function can solve BCBS 239 alone. Balancing end-to-end ownership, accountability, oversight, and expertise will test any siloed organisation. 

Where to start? Explore different ownership models like Amazon’s “Single Threaded Owner” or NVIDIA’s “Person in Charge”. These can help generate new approaches which, if tailored appropriately, can support effective design and delivery of complex programmes like BCBS239.   

Literacy: Organisations must develop a common language and mental models that underpin Data programmes. Without baseline data literacy, senior leaders may not feel equipped to provide constructive challenge, while colleagues often hesitate to jump on the necessary learning curve. 

Where to start?  Over-invest in developing common language and frameworks. Technology and Data teams may need to simplify their language, while Risk and Business teams may need to train colleagues in the core concepts and tools of effective data management. Secondments can accelerate data literacy for all parties.  

Change Fatigue and Lethargy: Change fatigue is real. So is the perception that the regulator has not ramped up enforcement measures. Yet. Both issues must be addressed head-on.

Where to start?  A clear vision from management, urgency and empowered colleagues, coupled with modern approaches to designing and delivering complex programmes, can create the necessary momentum. 

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