It’s often said that in every crisis there is an opportunity. And in the case of the financial crisis, the regulators, mandated by the G20, seized the moment. The crisis prompted a comprehensive overhaul of banking regulation. This was not just at a UK or European level but, through the G20 and the Basel Committee on Banking Supervision, these reforms became a global project.
The primary aim was to address specific issues that had been laid bare by the crisis. This was the first step. But regulators knew, of course, that the latest crisis is never a blueprint for the next one. The next crisis might come in a completely different form. So the second step was to enhance the general resilience of banks, to make them strong enough to withstand any type of storm. This idea underpins the three main building blocks of the reforms: capital, liquidity and governance.
Much has been done on these three fronts. Regulations have been put in place that mean banks not only have to hold more capital than they did before the crisis; but their capital also needs to be of higher quality. Banks can therefore suffer more losses before they actually fail. At the same time, banks have to fulfil much stricter liquidity standards than before, providing them with a cushion in case trust evaporates and funding dries up. This allows banks to survive in a crisis for longer than they could in the past.
Reforms to improve governance and risk management have also come about, but these have received less attention. For too long, governance and risk management have taken a backseat in public or academic debates. But they are just as important as capital and liquidity – if not more important. After all, good governance and sound risk management help to prevent a bank from getting into trouble in the first place. Capital and liquidity are merely backstops for bad management – or bad luck.
New regulations help and encourage banks to set up appropriate processes and integrate them into their organisational structures. In this context, one of the standards developed by the Basel Committee is somewhat under-appreciated. Specifically, the BCBS 239 Principles for Effective Risk Data Aggregation and Risk Reporting plays a significant role in adequately managing the risks of a bank. In order to make sound decisions, top management needs sound data.
The BCBS 239 Principles set out a standard for the larger, more complex financial institutions to work towards and in recent times larger domestic banks and other financial institutions such as larger brokers are also being asked to invest in this governance standard. Banks have made significant investments in the data capabilities needed to meet rising regulatory demands—yet they are still struggling to keep pace. According to banks’ own quantified self-assessments, overall compliance levels have actually declined since 2015.
At the top of the list of governance-related challenges are the increasing scrutiny that banks expect in the near future and the rising levels of investment needed in data and technology capabilities. These challenges can be met, however, if banks are able to create value from data as they tackle the governance agenda. In other words, the data vision and strategy that banks deploy to meet governance needs and contribute to overall safety and soundness also support business goals. While banks remain primarily focused on risk data compliance, a few have begun to also use the data strategically to support business growth through advanced analytics and digitisation.
The goals of governance and business value can be pursued simultaneously. Compliance efforts are leading to enterprise-wide data-quality controls and governance established on the same data has also been used that to yield business value. Through machine learning and other advanced analytics methods, high-quality, well-governed data will provide the basis for the insights which are needed to realise business value in a range of situations.
Supervisors have been meeting with banks’ boards of directors and senior management to obtain an update of the banks’ progress in their implementation of the BCBS 239 Principles and BCBS plans to conduct the next implementation monitoring exercises this year. In light of the current national and geopolitical stresses combined with an economic slowdown influencing the world markets, it will be interesting to see what progress they will report.
Richard Bennet is the CEO of Razor Risk. Rami Cassis of Parabellum Investments is the Chairman.