technology challenges of the new regulatory environment
TRANSCRIPT
Post Trade Forum & Trade Show NH Danube City Hotel, Vienna
Kerry Evans – 11th September 2015
Technology Challenges of the new Regulatory Environment
Regulatory impact analysis We’ve all got one of these.
9
2015
7 3 6 5 1 12 4 10 2 10 11 6 7 8 7 9 8 3 8 10 4 12 9 11 9 5 7 11 12 1 6 2 6 11 5 2 3 1
2017
1 4 2 3
2018 2016
4 12 5 10 8
31/8/16 FSB Phase 3 31/7/15 FSB Phase 2
1/1/18 IFRS 9 implemented
15/2/15 LCR deadline templates
30/6/16
AnaCredit Pilot 31/12/16 AnaCredit Compliance
30/6 /15 Remedial actions
AnaCredit
31/3/15 PoA DIV 31/1/15 PoA DNB
At least 1 a year At least 1 a year
Stress testing
Regulatory Topic
1/1/16 BRRD Minimum Required own funds and Eligible Liabilities
1/1/16 BCBS #239 compliance BCBS #239
AQR Rem Actions*
Liquidity reporting 1/1/16 Daily LCR
FSB**
IFRS 9
30/6/15 New templates ALMM
FTP
BRRD
28/2/15 CRD IV aftercare
1/1/16 Set up IT/Information System
31/12/16 Equity Framework
30/4/15 LGD changes
30/9/15 CRM & Netting
1/7/15 Asset calculation IHC EPS
FINREP
1/7/16 Compliance with EPS requirements
31/12/15 Stress testing UAH 21/7/15 Collins Amendment
Reporting on solo level (expected)
DPM 1/1/16 DPM 2.4
31/12/17 Securitisation Framework
1/1/17 DPM 2.6 1/7/16 DPM 2.5, 1/7/15 DPM 2.3 1/1/15 DPM 2.2
COREP
1/7/16 Full MMS reporting 1/4/16 Partial MMS reporting
1/10/15 New templates LCR
1/1/16 Apply SREP guidelines
At least 1 a year
SREP 13/4/15 SSM SREP
MMS 1/7/18 Net Stable Funding Ratio
At least 1 a year
* Solution DIV tbd ** Extension phase 1 tbd
Regulatory milestone Regulatory milestone, no fixed date Legend
What Changed
Connect to new market places
Pre-trade checks
Transaction
reporting
Clearing
House
connectivity
Financial Reporting
Revenues and Regulations Increased pressure on IT budgets
Technology debt observed in 2015 was largely caused by the application of a series of tactical bolt-ons or hacks to existing software platforms, often exacerbated by regulators failing to articulate, complete, unambiguous, quantitative, verifiable requirements in good time. In addition, our clients are in an environment where business leaders demand increased reliability, flexibility and the ability to quickly react to requests. * Greyspark
JP Morgan, Citi, Morgan Stanley, Goldman Sachs, Wells Fargo, Barclays,
RBS, Lloyds, HSBC, Standard Chartered
2008 -2015 –competing drivers Cost saving and regulation
Regulators Required :
Collect and consolidate information, cross asset and cross business lines
More complexity, more systems, more costs.
Business Required :
• Reduce costs,
• Cut surplus systems,
• Restore profitability
• Support new business
models
Know More Know It Better
Know It For Less
Crunch Point How much can we consolidate ?
Front Office
Back Office
Front to Back
Risk
Finance
The whole lot ?
• Set your project up to succeed
• Senior management support
• The right delivery team
• Business IT Partnership
• Stages for funding and delivery
• Strong project disciplines
• Short delivery cycles
• BE PREPARED TO CANCEL
• Pick your vendor carefully
• Product scope
• Credible road map
• Accessible skills in market
• Focus on the benefits
• It’s not all about IT – 95% is good enough
• Business processes – fit the system
• Business compromises (out of the box functionality)
• IT - 95% is NOT good enough
• Actually retire your systems.
• Focus on the quality
• Management reporting
• Decision making
• Deployment and support
• Plan, measure, report, replan
What do I need to consider? On average, large IT projects run 45 percent over budget and 7 percent over time, while delivering 56 percent less value than predicted. * McKinsey
• Change lifecycles for the future
• Front office changes vs. Risk System changes
• Avoid Version Drift
• Adopt Vendor releases and adapt business processes
• Rebalance of system ownership
• More partnership (& more committees)
• Wedded to one supplier
• 20 year relationship
• Concentration of suppliers
• Not many offering credible options
• Price of entry for competitors
• Standardisation
• Common business processes
• Common technological skills
• Common risk models
What are the implications? How could a monolithic IT architecture impact my business?
For My Firm For the Industry
Standard platform
Discrete flexible components (open source ?)
Standard inter-process communications
No-one is offering – although some of the elements exist
Is there an alternative? Can I fight the fashion
Outsourced entirely
Fully standardized platform
Fully standard processes
The utility solution
Coming soon from a vendor near you