Principles for Effective Risk Data Aggregation and Risk Reporting

12 important questions on Principles for Effective Risk Data Aggregation and Risk Reporting

What is risk data aggregation?

Defining, gathering and processing risk data according to the bank's risk reporting requirements to enable the bank to measure its performance against its risk tolerance/appetite. Including sorting, merging and breaking data.

What is the objective of FSB principles?

Strengthen a bank's risk data aggregation capabilities and internal risk reporting practices to enhance the decision-making process, primarily at board level. Expect to support:
- Enhanced infrastructure for key information
- Improve decision-making process
- Enhance MIS across legal entities
- Reduce probability of severe loss from RM weaknesses
- Improve speed/timeliness
- Improve quality of strategic planning
Complete other efforts and provide smoother bank resolution (primarily SIBs).

Topic I - Overarching Governance and Infrastructure

There should be a strong governance framework, risk data architecture and it infrastructure. The board should oversee this and coordinate timely implementation.
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Principle 2 - Data architecture and IT infrastructure

Design, build and maintain data architecture and IT infrastructure which fully supports its risk data aggregation capabilities and risk reporting practices in normal but also times of stress of crisis. Including:
- Business continuity planning
- Integrated data taxonomies and architecture across group
- Roles and responsibilities of ownership and data quality
- Adequate controls
- Ownership: data correctly entered, current, aligned and consistent with policies

Topic II - Risk Data Aggregation Capabilities

Banks should develop and maintain strong risk data aggregation to ensure that risk management reports reflect the risks in a reliable way.

Principle 3 - Accuracy and Integrity

Be able to generate accurate and reliable risk data to meet normal and stress/crisis reporting accuracy requirements, on a largely automated basis. Including:
- Controls for robustness
- EUC for manual processes (to mitigate risk)
- Reconciliation, preferably with accounting
- Single authoritative source for risk data per type of risk
- Dictionary
- Balance between automated and manual (reduce risk of errors), judgment
- Documentation (e.g. workarounds)
- Measure and monitor accuracy

Topic 3 - Risk Reporting Practices

Accurate, complete and timely data is a foundation for effective risk management. To manage risk effectively, the right information needs to be presented to the right people at the right time, in the right way. They should be accurate, complete and clear.

Principle 9 - Clarity and Usefulness

Reports should communicate information in a clear and concise manner. Reports should be easy to understand yet comprehensive enough to facilitate informed decision-making. Meaningful info tailored to needs of recipients. Including:
- Relevant recipient
- Balance on quantitative and qualitative
- Differing information needs
- Asking for and receiving info for governance
- Adherence to risk appetite
- Inventory classification
- Clear and useful
- Confirm with recipients regularly on relevance and appropriateness

Topic IV - Supervisory Review, Tools and Cooperation

Important role for supervisors in monitoring and providing incentives for a bank's implementation of, and ongoing compliance with the above principles.

Principle 13 - Remedial actions and supervisory measures

Appropriate tools and resources to require effective and timely remedial action by a bank to address deficiencies in its risk data. Including:
- Effectiveness and timeliness
- Increasing intensity of supervision
- Capital add-ons
- Set limits on deficiencies
- Watch new business initiatives
- Timetable for completion of deficiency and escalation procedure

Principle 14 - Home/host cooperation

Cooperate with relevant supervisors in other jurisdictions regarding 12 and 13. Including:
- Sharing knowledge
- Within constraints of applicable laws
- Colleges
- Experiences in different parts of the group (impediments)
- Identify concerns

Topic V - Implementation and Transitional Arrangements

Expect robustness and flexibility to address potential needs in normal and stressed times. Closing significant gaps before 2016. BCBS will track progress on principles.

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