Transforming data collection – Reporting Transformation Committee minutes - October 2021

The Reporting Transformation Committee will focus on overseeing the design of solutions for parts of the reporting process where the Bank, FCA and reporting firms interact directly. This will cover aspects of modernising reporting instructions and creating a better integrated end-to-end reporting process.
Published on 03 December 2021

Date of meeting: 20 October 2021
Location: This meeting took place via video/audio link

Minutes

Item 1 – Introduction

AM welcomed all to the meeting and recapped the actions from the previous meeting (approval of the September minutes; approval of the updated Terms of Reference). The Committee confirmed its approval of the minutes.

Item 2 - Project Plan

AB presented the current progress of the project plan – the project is on track. Form DQ discovery is ending and its alpha phase is beginning. Discovery work on the CRE and Financial Resilience Survey use cases is ongoing. The programme team has added a workstream on Common Services to the project plan. The Common Services workstream will look to identify solutions and services that it plans to scale across use cases.

Key Discussion Points/Comments:

  • KP asked if there is a schematic for the vision the team is aiming for regarding ‘integrated reporting’. AB stated that the team already have some generalisable issues and are starting to codify what the issues are. A high level skeleton of issues will then come out of this and the sessions to be held in December.
  • AT supported the idea of thinking and scaling through common services but cautioned that the current use cases don’t represent the full landscape. He felt the team shouldn’t generalise too soon as they might miss some key issues outside of the current set of use cases. AM assured the committee that work on common services is currently exploratory, and so there is scope for the design of any solution or service to evolve over time as the programme works through new use cases.

Item 3 - Financial Resilience Survey Overview

AB gave an overview of the ‘Financial Resilience Survey’ use case, which has been renamed from ‘RegData’. The use case aims to look at the potential for the current survey to become a regular collection and look at data quality and standards whilst minimising duplication.

Key Discussion Points/Comments:

  • AT asked what the role of the committee should be for deciding on new use cases. AM explained the current set of Bank of England use cases were selected as part of the Data Collection Review, after consultation with industry. He noted the process of deciding future use cases will involve consultation with the Reporting Transformation Committee.
  • Members questioned whether a new regular data collection was in scope of the programme. They had understood the focus of the programme was on changing how we collect data, not what we collect. They doubted whether changing collections would lower the cost of regulatory reporting to industry.
  • RD1 and AM clarified the scope of the programme. RD1 reassured members that this is an opportunity to shape and design the collection and also challenge whether it needs to become a regular collection. She added that regardless of whether the content of the collection changes, there may still need to be a material shift in how collections take place, such as moving from a form-centred collection design strategy to a data-centred one. Implementing these changes may be costly in the short run but lead to longer-term benefits. AM confirmed, from a Bank of England perspective, the scope of the work was to focus on how to collect data. But he noted there are challenges in separating the questions of what data is collected for, and how it is used, from how it is collected. He reminded members that, regardless of the solution, the point of the programme is to deliver effectiveness and efficiency for the authorities and industry, adding that any new collection will have to go through the normal consultation process.
  • GC emphasised the need to keep in mind the objective of the project as a whole. It will take time to reengineer how firms send data and for regulators to define a single set of data points they require. Until then the project should focus on small wins in order to help the team progress towards the overall aim. AM agreed that in order to transform data collection we have to invest early and look at use cases where the value is in enabling future value.
  • RP queried the value in creating a new report for the Financial Resilience survey. He argued it was not clear from the information presented how this activity links back to an agreed problem statement. He emphasised that there was a pressing need to collectively agree the high-level vision and problem statements that we are trying to resolve, noting the first objective in the in 2-year project goals discussed at the inaugural Transformation Committee meeting to create “a detailed shared understanding of the problems faced by all parties involved in the data collection process”. In RPs opinion this activity had not yet happened and needed to be resolved to ensure resources are used on the most valuable activities.

Item 4 – Commercial Real Estate Overview

SH gave an overview of the commercial real estate (CRE) use case and work underway. She said the team is looking at current data collections around CRE to understand the users and identify any current issues or potential overlaps with other collections.

Item 5 - Form DQ Problem Statements

EM presented a summary of the outputs from the Form DQ analysis week. The week consisted of analysis of findings from discovery so far, including interviews with the Bank of England (BoE), Office for National Statistics (ONS) and reporting firms. EM outlined the key issues identified and asked users to comment on which of the ‘how can we’ statements they thought were most important and if the team had missed any.

Key Discussion Points/Comments:

  • AT felt there were no gaps in the current list. He felt from the firm side, the most important areas were in the simplification and standardisation of form mappings.
  • RP agreed that it is important to ensure consistency by breaking regulatory data items into their components. Different firms might calculate data items in different ways so there is a need to keep reports low level rather than aggregating too soon. LM agreed and set expectations that the team will have to focus in a small area to start with in order to scale in future.
  • LF felt that it is important to evaluate the insight that regulators and the ONS require from the data in order to ensure that firms can provide the correct information.

ACT: Delivery team to add a ‘How can we’ statement: ‘How can we better understand the insight that users of the data are trying to derive?’

Item 6 - Risks and Issues

SH discussed the risks and issues. She highlighted resourcing, stakeholder engagement and the CRE use case approach as the most important risks currently.

Item 7 - Principles of Human-Centric Design

AM introduced the concept of human-centric design and the role it plays when developing services for end users. AM asked members to comment on whether they thought human-centric design should be a key principle for the programme.

Key Discussion Points/Comments:

  • AT supported the concept in general, but urged the team to consider that not all pain points can be uncovered by looking purely at the BAU process of the end user. There can often be pain points in implementation that shouldn’t be overlooked. Also, even if the end user at the firm end doesn’t identify any issues, there still may be data quality issues for the regulator. AM confirmed that the team will need to look at the needs of all users, including the regulators, and the service should be designed to meet all of these needs.
  • AT also highlighted the need for all solutions we produce to be scalable.

Item 8 - Postponing the Liquidity Metric Monitoring (LMM) Tool Use Case

AM proposed postponing the LMM use case due to limited resource in the delivery groups. The team believes it would be better to focus the efforts of the group onto the use cases already in progress.

The committee approved the decision to delay the start of the use case.

Item 9 - Vendor Engagement

AB outlined the current process for vendor engagement. The team wants to be open and get the perspective of vendors who have a wide range of experience and may have more specific insight on current issues faced by reporting firms for regulatory data collections.

Key Discussion Points/Comments:

  • LF agreed that there is a lot to be gained from engaging with vendors. However, the team needs to ensure that a vendor who produces a regulatory package isn’t the sole vendor involved as this may lead to a lack of innovation. The team should be engaging with a range of vendors and ensure that the regulators (BoE, PRA and FCA) own the IP of any solution developed.
  • GC felt that the main issue will be around data gathering and this might be an area vendors will struggle to come up with a solution. He felt we should aim to engage with a data provider that could help standardise client-specific data elements that need to be collected.
  • AT stressed that the team shouldn’t be speaking purely to RegTech vendors but should widen the scope depending on the needs of the use case.

ACT: Members to send contact details of any relevant vendors to the secretariat

Item 10 - Communications

AM gave an overview of the communication the team published on 30/09 which outlined the expected resource requirements from industry for the FY 2022/23.

Item 11 - Forward Agenda/AOB

AM presented the dates of the next committee meetings and ran through future agenda items including an update on the Reporting and Data Standards Transformation board and progress of the use cases.

AT requested that future meetings cover the process for deciding the next phase’s use cases and clarifications on the scope of the programme and role of the committee in offering recommendations.

Actions agreed in this meeting

  • Delivery team to add a ‘How can we’ statement: ‘How can we better understand the insight that users of the data are trying to derive?’
  • Members to send contact details of any relevant vendors to the secretariat.

Attendees

Andy Beale (AB), Financial Conduct Authority (Interim TDC Programme Manager)
Pardeep Bhatti (PB1), Metro Bank
Paul Burleton (PB2), BNY Mellon
Graham Cohen (GC), BNY Mellon
Jacqueline Davies (JD), TSB Bank
Rebecca Ding (RD1), Financial Conduct Authority (Transformation Programme Lead)
Richard Dunne (RD2), RSA Group
Dayo Forster (DF), Bank of England (Product Owner)
Lee Fulmer (LF), UBS
Sharon Howells (SH), NatWest (TDC Project Manager)
Sandy Leggeat (SL), Goldman Sachs
Elizabeth Maloney (EM), JP Morgan (TDC Project Manager)
Robert McBride (RM1), Lloyds Banking Group
Ruaidhri McInerney (RM2), Macquarie Group
Angus Moir (AM, chair), Bank of England (Transformation Programme Lead)
Derek Paine (DP), Mizuho International plc
David Palmer-Lewis (DPL), Principality Building Society
Kamal Patel (KP), Barclays Group
Robert Pengelly (RP), Nationwide Building Society
Charles Resnick (CR), ClearBank
Aaron Shiret (AS), Bank of England (TDC Secretariat / Data Standards)
Tammy Solomon (TS), Investec Bank plc
Robert Thickett (RT), Building Societies Association
Paul Thirtle (PT), NatWest
Andrew Turvey (AT), Belmont Green
Martin Udy (MU), Bank of England (External Engagement Lead)
Richard Walker-Smith (RWS), Bank of America
Rebecca Whitwam (RW), Bank of England (TDC Secretariat)

Apologies

Mark Hutchison, Scotiabank
Mark Jones, Cambridge & Counties Bank
Daniel Sadler, ABI
Angel Serrano, Santander
Simon Shapiro, HSBC

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