Bank Of England: Transforming Data Collection – Data Standards Committee Meeting Minutes – October 2021

Minutes

Item 1 – Introduction

AD welcomed all to the meeting. AS recapped the actions from the previous meeting (approval of the September minutes; approval of the updated Terms of Reference; DSC members to provide details of their use case experience; Secretariat to circulate use case details). The Committee confirmed its approval of the minutes. AS explained that some members still had not provided use case experience and committed Secretariat to circulate details to aid this.

Action: Secretariat to circulate details of use cases.

Action: Members to submit use case experience (no later than 17 November).

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 new workstream on Common Services to the project plan. This will identify solutions and services that the programme may be able to scale across use cases.

SH gave an update on the CRE use case discovery. The delivery team aims to identify the key data standards issues with the use case, through research, user interviews etc. The team is planning to have its analysis week in early November. Members asked for confirmation of the firms that the delivery team is currently interviewing.

Action: Secretariat to provide list of firms interviewed for CRE.

AB presented on the Financial Resilience Survey use case (previously referred to as the RegData use case). Discovery work has begun. The team aims to, by late November, identify relevant data standards issues for further discussion with the Committee.

EM gave a summary of the outcomes of the Form DQ analysis week, during which the team focused on understanding current problems from the user’s perspective. The programme is planning a deep dive session for the Committee to share the discovery results in detail.

Key Discussion Points/Comments:

• Members were keen for the Committee to get an understanding of the potential role of data standards in Form DQ solutions and contribute to solutions development.
• AB added that the different use case workstreams will generate a lot of discovery outputs in the next six weeks. He agreed that engaging DSC on the role of standards is important.

Item 3 – LMM use case

AM explained that, given the resources available, the project needs to optimise its work on priority use cases and avoid trying to do too much. The programme team plans to delay the work on the LMM use case (which was planned for this phase). The programme will present this proposal to the Reporting Transformation Committee for their approval (as the relevant body).

Item 4 – Definition of data standard

AD introduced a discussion on establishing a definition of a data standard and the problems data standards can solve. This will be the first of a series of discussions aimed at establishing a general framework of principles for the use of data standards. Establishing a definition of a standard, and how to apply standards is an important first step.

Key Discussion Points/Comments:

• AD suggested that a data standard should be open rather than tied to any provider. Members agreed that open standards are preferable to vendors selling a product.
• Members agreed that it was essential for standards to have a strong business case for their adoption. Typically, standards are for use in the business with master data or product data, allowing the firm’s core business operations to benefit. However, with products becoming more diverse, it is important that standards are simple enough to implement easily.
• Members considered interoperability to be a key consideration for standards. Multiple standards may be necessary to solve specific problems e.g. handling data for different asset classes. Rather than attempting to shoehorn a standard for all instances, it may be better to pursue variations that are interoperable.
• Members suggested that a standard does not need to have an ISO number to constitute a standard. They felt a standard ought to be clearly defined, accessible to all and useable in a natively digital format that enforces accuracy (not just a pdf on a website).
• Some members challenged the idea that standards need to be free and open to all. They suggested that ‘accessibility’ is more important than ‘openness’. Standards that come at a cost can achieve widespread adoption.
• Members considered appropriate user involvement in governance and ease of adoption as pre-requisite elements of a good standard. In addition, standards need to evolve at the right pace, with active user involvement.
• Members felt that standards development processes didn’t always engage with all relevant stakeholders. The client side is historically not as involved. Standards can be too complex to facilitate adoption by small entities. Standards must be sensitive to user needs.
• Members felt the structure of standards was important. Standard need purpose and clear implementation outcomes; they must be measurable or enforceable. This helps ensure completeness and accuracy of data.
• Members discussed how standards should apply to datasets. Some members felt that different datasets would need different standards, but standards should only exist where necessary. Standards do not need to align to regulatory datasets necessarily, but perhaps the product data underlying that. Standards affecting a particular dataset also need not be competing – they could be complementary..

Item 5 - Barriers to adoption of standards

AD introduced the next discussion. A big problem around standards is lack of adoption, even when good standards exist. The Committee discussed the reasons why this is.

Key Discussion Points/Comments:

• Members agreed that it is important that standards must primarily serve the business activities of firms, providing an incentive to adopt. Ideally, firms would implement standards in their business operations and then use them to give regulators data, rather than vice versa (particularly as regulatory reporting can exist in a silo).
• AD mentioned that a long-standing issue is that firms at any moment will be at different points of their system investment lifecycle. Standards may not be adopted if they are not recommended at the time a firm makes its investment. He asked how to solve this.
• Members agreed that they had experienced this issue. They spoke of the importance of getting market infrastructures etc. on board with standards, as these help to build a business case for adoption. They suggested that processes could be designed to ease the move to a new standard, so that the old method coexists with the new for a while.
• Some members felt that the role of regulators is important for adoption. If regulators mandate the use of certain (good quality) standards this would be a powerful ‘stick’. Others disagreed that this is the only way to make progress – they felt the determining factor was standards themselves – some work, some do not.
• AD commented that the question of mandating use of standards is an old issue discussed in other forums. Regulators tend to have a low appetite for mandating standards.
• AM noted the commitment the Bank made^footnote[1] to support the development and adoption of common data standards. He noted the Bank has a number of tools available to use to provide support; this includes mandating the use of standards for collections amongst others. But that the Bank has not committed to which of those tools it wishes to use where.
• Members spoke of the importance of international coordination. Cross-border firms will enthusiastically adopt standards that offer clear benefits for their business, especially when they can implement standards in more than one jurisdiction.

Item 6 - Communications

AM explained that in late September the programme published information on its expectations of industry involvement after March 2022. This includes work to develop a minimum standard service. The programme will conduct a ‘proof of concept’ on developing the tooling and services around a standard to make it useable and easy to adopt.

AM asked if the Committee had any preferences for how the programme should communicate with industry. Members encouraged the programme to engage with the industry as much as possible during standards development and to communicate in different formats.

Item 7 - Forward agenda / AOB

AS presented the dates of the upcoming meetings (including Form DQ deep dive) and presented the forward agenda, including discussion of discovery outputs.

AM added that in future DSC would also discuss the programme’s Data Standards Review and proof of concept work.

Action: Secretariat to invite DSC members to deep dive session about Form DQ.

Actions agreed in this meeting

• Secretariat to circulate details of use cases
• Secretariat to provide list of firms interviewed for CRE
• Secretariat to invite DSC members to deep dive session about Form DQ
• Members to submit use case experiences (no later than 17 November)

Attendees

Ffion Acland (FA), Goldman Sachs
Julian Batt (JB), Bank of America
Andy Beale (AB), Financial Conduct Authority (Interim TDC Programme Manager)
Rebecca Ding (RD), Financial Conduct Authority (Transformation Programme Lead)
Andrew Douglas (AD, Chair), Depository Trust and Clearing Corporation
Lee Fulmer (LF), UBS
Dayo Forster (DF), Bank of England (Product Owner)
Dawd Haque (DH1), Deutsche Bank
Dave Holland (DH2), Coventry Building Society
Sharon Howells (SH), NatWest (TDC Project Manager)
Paul Jones (PJ), Nationwide Building Society
Neil Kirkham (NK), LME
Caroline Lewis (CL), Lloyds Banking Group
Elizabeth Maloney (EM), JP Morgan (TDC Project Manager)
Angus Moir (AM), Bank of England (Transformation Programme Lead)
Corinne Powley (CP), Phoenix Group
Lewis Reeder (LR), BNY Mellon
Angel Serrano Buces (ASB), Santander
Aaron Shiret (AS), Bank of England (TDC Secretariat / Data Standards)
David Shone (DS), International Securities Lending Association
Ian Sloyan (IS), International Swaps and Derivatives Association
Nicholas Steel (NS), Barclays Group
Emma Tan (ET), JP Morgan
Andrew Turvey (AT), Belmont Green
Martin Udy (MU), Bank of England (External Engagement Lead)
Richard Young (RY), Bloomberg

Apologies

None