With the RDARR-Guide, the ECB clarifies and further specifies expectations regarding BCBS 239 requirements. However, the guide does not define concrete criteria for determining the scope of application, creating interpretive leeway and implementation challenges. In this whitepaper the authors examine practical hurdles in defining the scope and explore pragmatic, fit-for-purpose approaches.
Most banks use an expert-based approach that is coordinated by a central function, typically the central data governance function. One of the main challenges is identifying in-scope reports, as banks often lack a standard definition and a central inventory of reports. Additionally, the supervisory requirement of explicitly including key risk models in the scope of application imposes the challenge to assess their relevance and determine how the different phases in the model lifecycle have to be considered in data management.
Once relevant reports and models have been identified, selecting relevant KRIs and CDEs becomes essential. These interdisciplinary tasks require the involvement of different units, therefore one of the challenges is to ensure a consistent, bank-wide level of implementation, which can only be achieved by central guidance and a collaborative approach.
To enable a clear business advantage, data management requirements should not be limited to the bare regulatory minimum but instead applied across the entire data landscape. By tiering requirements based on criticality and materiality, banks not only fulfill supervisory expectations, but also strengthen analytics and AI readiness, and foster a resilient, data-driven organization prepared for future challenges.
You can download the complete white paper at the top of this page.
Verfasst von
Dr Philipp Altmeyer, Manager & Expert in Data Management
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Dr Sascha Hügle, Partner & Expert in Data Management
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Maik Schock, Senior Manager & Expert in Data Management
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Dr Ingolf Segger, Senior Manager & Expert in Data Management
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