What Data Governance in Banking Must Prove for CCAR and BCBS 239
Blog post from Foundational
Banks face significant challenges in meeting the Comprehensive Capital Analysis and Review (CCAR) and Basel Committee on Banking Supervision's BCBS 239 requirements, which demand stringent proof of data accuracy and lineage rather than mere documentation. These standards require banks to provide a verifiable and reproducible path showing how risk and capital planning data are generated and transformed from their original source systems to final reporting, a process not satisfied by warehouse-level lineage alone. Established banking systems, often comprising legacy core platforms and newer cloud infrastructures, complicate this task as data frequently moves through multiple systems and transforms, which can obscure its origin. BCBS 239, introduced in response to the 2008 financial crisis, emphasizes the need for reliable risk data aggregation and risk reporting capabilities, while CCAR focuses on the verifiability of capital planning submissions. To comply, banks must leverage tools like source code analysis to map data lineage directly from the systems and application code that generate and manipulate data, ensuring an evidence trail that withstands regulatory scrutiny, thereby transforming regulatory reviews into straightforward verifications rather than protracted negotiations.
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