The Long and Winding Road of Regulatory Compliance

CCAR 2013 results are out. While most of Bank Holding Corporations (BHCs) have exhibited strong capital resilience to stress tests, 4 out of 18 BHC need attention in their capital plan or capital planning process[1]. In 2012, the picture was similar. Most BHCs had adequate capital ratios; however 4 of the 19 BHCs had one or more projected regulatory capital ratios that fell below regulatory minimum levels at some point over the stress scenario horizon[2].

At Axtria, we have been spending a lot of time thinking, what needs to be done here – What exactly do BHCs need to put in place to meet Fed’s capital adequacy planning requirements. And as with all large complex problems, the answer, according to us, lies in the simple fundamentals:

1. Get a solid ‘bedrock’ of data: Accurate financial data mart is super critical (it’s like the bed-rock!) to stress test the portfolios. It needs significant investments in tools and infrastructure to standardize and accurately aggregate the different data sources. Our experience suggests that even with significant investments, if the data strategy efforts are not holistically thought out, the results are mediocre. It results in non-standardized, ill-aggregated data which is one of the fundamental drivers of missing regulatory needs.
2. Build robust monitoring mechanisms: BHCs need better reporting on the results of internal stress tests. This is particularly true for the evolving methodologies, which need information on a lot of model parameters. BHCs also need to capture and report information on the assumptions used to derive fair value, as well as on macroeconomic parameters which typically come in from external vendor’s data feeds. These challenges are not just IT ‘fixes’. To us, these are strategic priorities – something which should not optimized ‘locally’ – something that needs ‘global optima at an enterprise level’.
3. Compliance journey is iterative and long: Regulations keep evolving and guidelines and requirements keep increasing! It is critical to adopt a flexible methodology. Having a clear roadmap identified, with potential pit-stops where wheels can be changed easily would be mission critical. And guess what, these pit-stops are nothing but having access to most granular data and open / flexible architectures to manage it. Essentially, the regulations will continue to evolve beyond Basel III and you want to ensure your systems and data aggregation mechanisms are adaptable to meet these needs.

At Axtria, 150 of us get up every morning and think about these problems for our clients’ day in day out. How do we make aggregated data available at a ‘click of a button’? How do we get the most granular and accurate reports published across the client departments without a scramble? How do we ensure the technology architecture and data models are flexible and modular? How do we institutionalize model validation and regulatory compliance procedures? How do we ensure the risk management framework is sustainable and world-class? We’ve got some thoughts! 30 Fortune 500 companies hear those continuously. 

About the Author:

Amanjeet Saluja is a Principal with Axtria. He has over 14 years of experience across analytics and management consulting. In his career, he has built 2 analytics units from scratch and scaled them to multi-million dollar business lines. His specific area of focus has been Risk, Marketing and Operations Analytics for Banking and Financial Services clients. 

Axtria is an advanced analytics company that combines industry knowledge, analytics and technology to deliver solutions that help companies make better data-driven sales and marketing decisions, with measurable results.

[1] Source: Comprehensive Capital Analysis and Review 2013: Assessment Framework and Results, March 2013, Board of Governors of the Federal Reserve System