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Yiota Andreou
Email: Yiotaa@marcusevanscy.com 
Telephone: +357 22849 404
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8th Edition 
Risk Data Aggregation and Risk Reporting  

24th – 26th April 2019
De Vere Holborn Bars, London, United Kingdom 

How does ensuring sustainable compliance with BCBS 239 create a need for organizational change?

The financial crisis in 2007/2008 highlighted the poor data practices prevalent in the banking industry at the time. The release of the BCBS 239 principles was a direct response to this. At its core BCBS 239 is all about Data Management 101 good practise. Complying to BCBS 239 is however not a point in time solution but an ongoing exercise. The management of data, including the remediation of poor data and associated processes, is ongoing and requires one to have the right structures in place, clearly defined data management disciplines and the appropriate data governance.

Data and information are the lifeblood of the 21st Century economy. No enterprise can be effective without high quality data. Today’s organizations rely on their data assets to make more informed, and more effective decisions:
•Market leaders leverage their data assets by creating competitive advantage through greater knowledge of their customer’s innovative usage of their information and operational efficiencies.
•Businesses use better data to provide better quality products and services, cut costs and control risks.

Yet for many important decisions we experience data information gaps i.e. the difference between what we know, and what we need to know, to make an effective decision.

Information gaps represent information liabilities which can potentially have a profound impact on operational effectiveness and profitability. It can be tempting to think that our organizations are struggling through a lack of data. The reality is that most of us have more than enough (data) to make insightful decisions, but the data is poorly managed and exploited.  
What becomes clear is that organizations need to become data centric if they wish to survive in the age of information. Data ownership becomes critical and the embedment of good data disciplines requires an organizational change. Data Management should no longer be something that someone does as a sideline; it needs to be ingrained into the organization’s operational fabric. To be truly successful in managing data in the Information Era it is necessary to define and create appropriate data management roles and assign responsibilities within an appropriate Data Management Organizational (DMO) structure.

How can the introduction of a Chief Data Officer help to make good risk data governance a priority throughout the whole bank? 

Chief Data Officers have gained popularity in Financial Services where the role emerged in the aftermath of the financial collapse of 2009. It was evident to both the banks and regulators that insufficient attention had been paid to managing their data. They realised that if they had been more effective in managing this critical asset it might have provided a warning of the forthcoming meltdown or, at a minimum, assisted them with a more resilient response.

There was a recognition that banks needed a senior executive who could drive the data management strategy throughout the organisation in order govern critical data assets appropriately. Importantly, this role required someone with a balanced understanding of the institution’s core businesses, products, customers, and supporting data infrastructure’s capabilities and needs. This is a different skill set to that of a typical Chief Information Officer or Chief Technology Officer.

Financial Institutions have increasingly come to recognize that their data assets represent highly strategic sources of insight that can be leveraged for a wide array of business functions. These include sales and marketing, product development, risk management, regulatory compliance, and of course operational performance. Business has realised that this “embedded” value in their information assets needs to be proactively and effectively managed from an enterprise perspective, breaking down silos where they exist.

Chief Data Officers provide this strategic guidance to the organisation. They assist in establishing and embedding data management execution capabilities thereby ensuring access to quality data. They play a strategic role in helping Financial Institutions to adapt and transform their data ecosystems in response to rapid technology innovation, new market entrants and non-traditional competitors.

What are some of the challenges involved in introducing a CDO?

Introducing a CDO into an organisation brings with it many challenges. Starting at the senior levels one may need to defuse territorial issues before they start. Fostering a positive relationship between the CDO and the CIO functions is imperative. Since banking business functions traditionally haven’t had the resources, or indeed a leader, to engage in data-related agenda-setting, technologists have grown to own data dictionaries, analytics, and other data related activities. In the era of information, the CDO is increasingly assuming these responsibilities. This can create friction that needs to be carefully managed.

The CDO needs to balance enterprise and business unit goals for data sourcing and usage whilst at the same time complying with increasingly demanding regulations around data availability and quality. They need to establish meaningful metrics to measure the success and effectiveness of enterprise data management activities and show sufficiently positive results to maintain the required stakeholder support and funding.

Technology challenges are ever present as the CDO faces increasing data volumes and complexities. On the one hand they need to keep pace with increasing IT innovation but at the same time they need to deal with the complexity that comes with legacy systems. It is critical that the CDO works closely with the Chief Information Officer to ensure alignment and consistency in their vision from a data and technology perspective. They need to agree on a data-focussed technology roadmap, leveraging emerging technologies such as Big Data, Blockchain, robotics, cognitive analytics, etc., with the ultimate objective being to derive business benefit from data and analytics.

Then there the people challenges. These can include educating stakeholders, especially board members and other senior executives, about the need for, and value of the CDO (and the accompanying data management disciplines), that goes beyond regulatory compliance. The CDO needs to build trusted relationships and overcome conflict. This is particularly challenging when other departments may not want to relinquish control of their data. Lastly, they will need to hire and develop individuals with the right balance of information management and business skills to drive the CDO office vision. 

What are other measures that can be taken to help improve data management and data governance practices?

Whilst the obvious things to have in place would include Data Management Policies, Frameworks, embedded data management practices, properly constituted data teams, (including specialist areas such as Metadata Management and Data Quality Centres of Excellence), the battle will never be won without getting some key basics right.

Data ownership is often a stumbling block and therefore the data ownership model needs to be clearly articulated. It is often useful to explain what ownership means in different contexts, to different areas and individuals, by using real life examples.

A strong communication and change management plan is critical to the success of the data management strategic initiatives and is key to maintaining the buy-in from the broader organisation. Continually educating business as to what it means to be a data centric organisation and showing the positive results of these activities are non-negotiable if one wants success.

Minimising any resistance that may arise whilst transforming the business into a data centric organisation is key. A good way to approach this is to emphasise to employees that they are already practising data management in their current day to day jobs. They may not recognize it as data management but, within the context of the job they do, they are dealing with data all the time and they know what is important about this data to complete their tasks successfully. The CDO teams job is to educate the employees on sound data management practises that they can then leverage to do their jobs even better. This will include giving them training on tools and techniques that make their jobs easier. At the same time, one can give them insight into how the data they deal with daily is used elsewhere in the business and thereby highlight the impact their data has on the rest of the organisation.

What would you like to achieve by attending the 8th Edition Risk Data Aggregation and Risk Reporting Conference? 

My intention in attending the conference is to learn from, and share my own insights with, other participants at the conference and discuss the common challenges we all face in addressing BCBS 239. I would like to hear from other organisations as to how they have approached and hopefully solved some of these challenges, including building data centric organisations that look beyond pure BCBS 239 compliance.



An interview with:


Michael Keegan

Head of Data Governance at Nedbank

As the 1st January 2019 deadline for BCBS 239 is closing in on DSIBs it becomes clear that none will be fully compliant, especially since implementation plans are expected to run till 2020. When it comes to the GSIBs, the January 2016 deadline has already come and gone - but where has this left things? Most GSIBs are now materially compliant, working towards being fully compliant, but it is difficult for all banks to understand what exactly being fully compliant means when the risk data aggregation and reporting regulation is principles based, with not only one way to deal with it. Progressing towards full compliance is tricky with a big regulation impacting more than just reporting, but also data management in the both risk and finance departments (the fundamental areas of a bank). At this point in time banks will be looking to confront self assessment of what they have implemented in order to improve processes but it is difficult to know exactly what the regulators want when Basel and ECB are not agreed on their views of BCBS 239 implementation. With this in mind, in this marcus evans conference we will look at the continued efforts placed to achieve sustainable and full compliance of BCBS 239 with focus on data lineage, taxonomy and consistency.

To view the Conference Agenda, click HERE! 

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About the conference

How does ensuring sustainable compliance with BCBS 239 create a need for organizational change?

We would be delighted to provide you with more information on the conference agenda.  Please fill in your details below and we will be in touch.

Michael is a driven executive with an extensive track record in the Financial Services Industries.  For much of this time (20 years) he worked at Rand Merchant Bank (RMB), a division of FirstRand Bank, occupying a number of roles.  His career within the organisation provided him with a unique understanding of the organisation and its strategic and operational drivers. His specialist areas included Strategy, Risk Management, Portfolio Management, Information Technology, Operational Management and Thought Leadership.

In 2015 Michael started working as an independent consultant. Originally contracted to Deloitte, he advised Nedbank on their Basel BCBS 239 implementation. In 2018 he was appointed as the Head of Data Governance at Nedbank and presently heads up the new Data Risk team under the Group Strategic Risk function. 

To view the Conference Agenda, click HERE! 

To view the Conference Agenda, click HERE! 

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