Bank Of England: Transforming Data Collection – Reporting Transformation Committee Meeting – 30 March 2022

Minutes

Item 1 – Introduction

AM welcomed everyone to the meeting and recapped the actions from last time (TDC Secretariat to clarify the role of the committees in the delivery process; Secretariat to invite committee members to working group sessions and committee members to volunteer / invite further volunteers from their firm). He highlighted that the role of the Committees in the delivery process would be covered later in the meeting and that the Committee working groups had taken place throughout March.

The minutes from the 2 March meeting were approved.

Item 2 – Project Plan Update

AB gave an update on the progress of the project. He highlighted that progress has been made on all use cases, with Form DQ and FRS developing recommendations and CRE still working through testing of their alpha solutions.

He went on to explain that the team is currently planning how to ensure they allocate the time remaining to the most important thing for a start date of September 2022 for Phase 2. He noted that there have been some issues with resourcing, particularly with absence and sickness on the team.

Item 3 – End of phase 1 process

AS explained that the purpose of this meeting was to give the Committee an initial view of the recommendations. In the coming weeks, they will then circulate a formal draft of the recommendations proposal to the committee. The committee will then have time to read the draft and propose changes. The Secretariat will work with the delivery team to create an updated draft, which they will then circulate again for any final comments and approval from the committee.

The committees will publish their recommendations and the Bank and FCA will consider their response. In making any decisions about changing their data collection operations, the regulators will need to go through internal governance. They will then publish their response to the recommendations. The programme team will keep a regular cadence of meetings with the committees during this period, and will consult the committees as appropriate, including feedback on consultation papers that may be required.

Item 4 – Phase 2 use cases

AM highlighted which of the Bank of England use cases are in scope for phase 2 of the programme (Asset reporting for insurers; Incident and outsourcing and third-party reporting; Commercial real estate). CC then explained the FCA use cases that will be included (Retail banking business model data; Strategic review of prudential data collections from solo regulated firms). He explained that although ESG was a popular use case, there was not currently enough internal resource available within the FCA to facilitate it.

Key discussion points / comments:

• RP explained that he felt it is unclear how the list of use cases was selected and that this has been done from the regulator’s perspective rather than as a collaborative process. He requested that the strategic priorities and principles for use case selection are made public. CC clarified that the team has looked for scaling opportunities and also discussed principles for use case selection at the Reporting and Data Standards Transformation Board. He confirmed that these would be shared more widely. He added that available internal resource from the regulators was a key part of the decision.
• AT queried whether regulatory disclosures were currently in scope of the programme as they are very closely linked to reporting requirements. He suggested that if they are not already included that perhaps this is something to consider. AM responded that this was definitely something to consider for the future of the programme.
• AT asked if the start date of the use cases will be staggered as they were in phase 1. AM explained that the plan is to start them all together in September when phase 2 kicks off.
• SL commented that it is important to engage with the ongoing work on ESG, before it is too late to work on the data collection process.

Action: Secretariat to share principles and strategic priorities considered when selecting use cases with the Committee.

Action: Secretariat to consider increasing the scope of the JTP to include regulatory disclosures.

Item 5 – Financial Resilience Survey: Draft recommendations

CC gave a recap of the FRS use case and went through the problem statements identified in discovery, and the solutions developed to address them. He introduced the recommendation for RegHub portal & homepages: the FCA should implement a web-based portal which firms can use as a single point of contact with the FCA.

Key discussion points / comments:

• CR questioned what the strategy is for the long-term mastering of data and ensuring that we don’t recollect the same data points across multiple reports. CC emphasised that the future scaling strategy is something that needs to be developed and included as part of the long-term recommendation.
• AT commented that he agrees with this recommendation and that there is internal support from his firm.

CC introduced the recommendation for the ‘Firm view at a glance’ solution: the FCA should implement a feature to enable the reflection of data submitted to firms back to them with suitable visualisation and contextualisation.

Key discussion points / comments:

• AT agreed with the recommendation and felt that it would be very helpful to firms and is easily scalable. He suggested a number of additional elements to include in the recommendation: FCA provide clear guidance on their expectations of firms re use of this tool; FCA establish process to allow supervisors to flag outliers or significant movements; tool should be usable for draft returns; FCA must ensure it protects confidentiality of other firms’ data; FCA should publicise tool and monitor uptake.

CC introduced the Future Financial Resilience Survey recommendation: the FCA should build the redesigned Financial Resilience Survey into RegData with manual checks used to identify duplication of questions submitted elsewhere.

Key discussion points / comments:

• AT questioned whether there was a choice to include this as a recommendation or not. He felt he was unsure whether it was appropriate for the Committee to recommend this. CC explained that the data is intended to be collected going forward, and that this recommendation is being made to reduce the number of collected points and firms in scope of the programme.
• RP asked how this recommendation transforms data collection and why it should be a part of the TDC project. CC explained that this has reduced the number of data points and firms included in the collection which is then changing the FCA’s decision making process. AM clarified that the team needs to clarify the principles that led to the reduction in data points, and then recommend these principles as these are scalable.

CC introduced the Templated Form Design recommendation: FCA to implement a more intuitive form design with improved access to relevant information about the specific data request being completed for future data collections.

Key discussion points / comments:

• AT expressed that he found this recommendation to be the least persuasive and scalable. He added that the team needs to think more about what the recommendation is more specifically. CC agreed to set up a workshop for the Committee members to discuss the recommendation once it has been drafted.

Action: Secretariat to hold workshop to clarify the recommendations for the FRS use case.

Item 6 – Form DQ: Draft recommendations

EM gave an overview of the Form DQ use case and explained how the problem statements identified in the discovery phase were tackled by the solutions developed. RM1 then presented recommendation #3: improved BoE website user experience. He explained that the recommendation was for the Bank of England to introduce a new website format with improved search function and an explanation of the use of data.

Key discussion points / comments:

• AT highlighted that will be important to look at how recommendations across use cases overlap and identify scaling opportunities. EM agreed at there are some themes emerging from phase 1 that should be documented across all use cases but that the work would not be duplicated.
• AT asked how some of the features such as the live helpdesk will age with advancements in technology. LM clarified that this is a tactical solution and intended to be implemented as soon as possible. She added that making the user experience more dynamic and responsive is something to carry forward to look at further in future use cases.

EM presented an overview of the other two areas of recommendation for Form DQ: counterparty classification standardisation and Form DQ attribute definitions & standards.

Key discussion points / comments:

• RM2 stressed the importance of communication with other jurisdictions around their plans for attribute standards. He explained that in some other countries, this has been moving towards LEI and SIC code. EM agreed that international alignment was important and that the team didn’t want a UK centric solution.
• AT supported these recommendations and asked how they fit into the phase 2 use cases. AM explained that data standards are a big scaling topic and something that will be carried forwards from phase 1 into phase 2.

Item 7 – Commercial Real Estate: Update

SH gave an update on the CRE use case and explained that it was on a slightly different timescale, particularly now that it has been selected to continue as a Phase 2 use case. She explained that the group has generated solution ideas and held working group meetings with some committee members who had offered valuable feedback. She clarified that the investment cases are in progress and there is still work to be done with a reduced team before phase 2 commences.

RD gave an overview of solution feature #1: design an integrated future-proofed regular data collection. He explained that all of the other solution features are dependent on this new collection being developed as the current collection is being phased out.

Key discussion points / comments:

• RP expressed support for the proposal and stressed that this use case should be used to investigate wider elements of a proposed operating model for future data collection.

MA gave an overview of solution feature #5: market analytics. He explained that existing analytics need to be improved in order to offer more value to regulators and firms. He added that this solution feature is an opportunity for scaling as there is a lot of overlap with solution features from the other use cases.

Item 8 – Phase 2 recruitment

AM explained that the recruitment drive for phase 2 is underway and that the programme needed more resource to support the next phase. He went through the lists of roles we are recruiting for and asked members to identify resource they could commit to the programme.

Key discussion points / comments:

• TS asked if there is a nomination form that will be sent out and if firms would be able to allocate people to specific use cases. AM confirmed that there is a new nomination form being developed that will be sent out shortly and that firms will be able to allocation people to specific use cases.

Actions agreed in this meeting

• Secretariat to hold workshop to clarify the recommendations for the FRS use case.
• Secretariat to share principles and strategic priorities considered when selecting use cases with the Committee.
• Secretariat to consider increasing the scope of the JTP to include regulatory disclosures.

Attendees

Matthew Ash (MA), Barclays (Delivery Group Member)
Andy Beale (AB), Bank of England (TDC Programme Manager)
Paul Burleton (PB), BNY Mellon
Chris Caldwell (CC), Financial Conduct Authority (Transformation Programme Lead)
Jacqueline Davies (JD), TSB Bank
Rob Dunse (RD), Lloyds Banking Group (Delivery Group Member)
Sandy Leggeat (SL), Goldman Sachs
Elizabeth Maloney (EM), JP Morgan (TDC Project Manager)
Robert McBride (RM1), Lloyds Banking Group
Ruaidhri McInerney (RM2), Macquarie Group
Angus Moir (AM, chair), Bank of England (Transformation Programme Lead)
Derek Paine (DP), Mizuho International plc
Robert Pengelly (RP), Nationwide Building Society
Charles Resnick (CR), ClearBank
Daniel Sadler (DS), ABI
Aaron Shiret (AS), Bank of England (TDC Secretariat / Data Standards)
Tammy Solomon, Investec Bank plc
Robert Thickett (RT), Building Societies Association
Paul Thirtle (PT), NatWest
Andrew Turvey (AT), Belmont Green
Martin Udy (MU), Bank of England (External Engagement Lead)
Andreas Viljoen (AV), Bank of England (Senior Manager, Reporting, Disclosure, Data and AI)
Richard Walker-Smith (RWS), Bank of America
Rebecca Whitwam (RW), Bank of England (TDC Secretariat)

Apologies

Pardeep Bhatti, Metro Bank
Graham Cohen, BNY Mellon
Richard Dunne, RSA Group
Mark Hutchison, Scotiabank
Mark Jones, Cambridge & Counties Bank
David Palmer-Lewis, Principality Building Society
Kamal Patel, Barclays Group
Angel Serrano, Santander
Simon Shapiro, HSBC