Thursday, July 7, 2011
Pressed for time; many institutions, even of large size, so consider the use of market solutions. However, uncertainties remain to be addressed regarding the maturity of the editors on this subject, including the ability to manage solutions in standard multiple levels of consolidation within international institutions. Nevertheless, difficulties in producing reliable and comprehensive reports on time are perhaps to be expected.
Reporting related to the Cooke ratio was traditionally produced and controlled by the Finance Department. However, since the implementation of Basel II and McDonough, new entities are involved in solvency calculations which are at the heart of the PRC.
This is the case of Risk Department, which focused knowledge of the risk-weighted assets for credit risk and operational risk (part of the calculation of McDonough). But it is also the case for Directions marketing, which often position themselves as providers of the data used for scoring Basel counterparts (also conditions the new ratio, for institutions using the "IRB").
It is therefore necessary to define now the control process and clarify the appropriate "service agreements" between the various entities. Indeed, the solvency ratio is at the heart of communication facilities and must follow a control circuit, validation, monitoring and operation, prior to its release or its internal operational use. In addition, aspects related to training will not be negligible in the success of the PRC, each actor in the "production line" to control the origin and impact of data it processes.
Therefore, the use of XBRL (data interchange format for technical interoperability) does not appear to be at the heart of the concerns of the banks. After all, it is only a computer translation of functional data model. This language is, moreover, already common in some international companies for internal reporting...
Generally described as a technical project, including the use of exchange format "XBRL" PRC also includes business and organizational issues are often overlooked. Yet they are at least as important and appear to be at the heart of institutional concerns. The establishment of "production lines" PRC, as well as has responsibility for validation and controlling data, indeed require special attention.
From a business perspective, it is primarily the availability and reliability of data on the scope anticipated at the heart of the concerns. On the one hand, Basel II, which must come to power PRC data are not yet stabilized for most institutions (upgrades following the regulator's audits, review the quality of some data, adjusting assumptions modeling, implementation delayed for certain subsidiaries ...). On the other hand, some data expected by the PRC are not provided in standard areas of specific ventilation, presence of aggregates under Pillar II, or references to IAS
A "simple" translation between the PRC and the Basel II appears to be excluded, especially since it must incorporate data from the subsidiaries. The complexity of implementation is also increased for banking groups with entities abroad. In Europe, there will be no one single reporting. On the basis of a reference format defined by the CEBS, each national supervisor has established its own version of the PRC. Therefore, the parent company cannot simply broadcast a unique methodology and to manage complex rules for consolidation and verification. A true "challenge" for groups ADDITION consolidating subsidiaries is not subject to the PRC, nor even to Basel II.
Once key issues arise with regard to functional architecture; indeed, the options selected will be structural, not only because the PRC requires complex treatment (IRB cohabitation methods and standard collection of market risk, high volume ...) but also because it will be necessary to ensure the sustainability of production assumptions (audit ability and interpretability of data on the long term).