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BUSINESS
APPLICATION
INTEGRATION
COMPLIANCE
REPORTING
TRADING
RISK
BUSINESS
APPLICATION
INTEGRATION
Time to untangle the regulatory spaghetti -
Avoiding the minimum viable compliance trap
with new approaches to data management
3Executive summary
Executive summary
COMPLIANCE CROSSROADS
TACTICAL AND
READY NOW
STRATEGIC AND
READY FOR THE
LONG-TERM
Are you set up to identify synergies within
the current regulatory data and system
requirements?
As firms continue to be hit with new
regulations, the pressure is on to navigate
the maze of new data requirements. Firms
no longer have the luxury of tackling one
piece of regulation at a time, and the
wave taking the market by storm appears
to be never-ending.
In fact, the focus on improving
automation and streamlining processes
appears to come second as firms now
strive to hit fast-approaching deadlines.
The project teams tasked with making
the necessary changes to ensure a firm
is compliant are typically focused on a
single specific regulation and then simply
source the data and systems to solve that
problem. With this approach, firms fail
to identify overlapping data points and
risk potentially reporting on different
numbers in different regulatory reports.
Still, few are concerned about data
duplication and siloed approaches and,
despite not having systems in place
months before a regulatory go-live date,
there is confidence in the market that
becoming compliant is achievable. The
worry is that, when the aim is to hit a
regulatory deadline and avoid fines, doing
the bare minimum to comply does not fit
in with strategic planning and long-term
operational goals.
This regulation-intensive environment
means firms have two options—to
continue to add more head count
and implement tactical systems
and processes to comply with new
requirements, or to identify ways to
work across project teams and find
ready-made services that can be
implemented quickly and to acquire
regulatory data more efficiently.
The latter option is the direction in which
the majority sees the market headed
and, according to a SIX survey, more
than 70 percent feel there could be more
opportunities for coordinating regulatory
projects and defining synergies between
regulations affecting the business. The
survey revealed that firms continue to
operate in a siloed environment and lack
the ability to take an enterprise-wide view
of regulation, which could hinder firms in
hitting regulatory deadlines and ensuring
reports are underpinned by quality data.
The reality is that the market is
overwhelmed by the amount of regulation
affecting business, and the main method
of dealing with regulation is still to
increase head count. Increased head
count, however, does not necessarily
help firms ensure robust data quality,
and having more personnel managing
data may be affecting data quality rates
as increased manual intervention further
hinders automation.
4 Introduction
One of the basic principles of construction
is to build walls before erecting the roof—
unless it is about putting up a temporary
cover to protect the building site in a
rainstorm. When it comes to regulatory
compliance it seems as if firms easily
forget to build their walls before the
roof—or they simply make do with a
temporary rain cover. In many cases, the
‘building foundation’ seems to have been
forgotten as firms become overwhelmed
by the wave of regulation and lose focus.
In the past, firms had more time to
focus on each major new directive, as
there were fewer regulatory deadlines
to meet in the same year. Now, many
organizations will be dealing with
everything from Europe’s second
Markets in Financial Instruments Directive
(Mifid II) and Packaged Retail and
Insurance-based Investment Products
regulation (Priips), and the US’s Foreign
Account Tax Compliance Act (Fatca) to
Switzerland’s Automatic Exchange of
Information (AEOI) and Financial Markets
Infrastructure Act (FinfraG) all at the
same time. Considering the trend of
multiple regulatory deadlines arriving on
a similar time horizon, it is not surprising
that many organizations are showing
signs of “compliance fatigue”.
Introduction
According to an exclusive SIX survey
of more than 100 senior industry
professionals representing buy-side
and sell-side firms, respondents found
it difficult to identify which regulation
was currently the most important for
their organization to address. The result
suggests that most firms are trying
to fight fires on all fronts to keep on
top of compliance obligations as non-
compliance is not an option (figure 1).
MIFIDII,PRIIPS,SOLVENCYII
AEOI,SANCTIONS
REGULATORYCOMPLIANCE
REGULATORYCOMPLIANCE
REGULATORYCOMPLIANCE
PRIIPS,SOLVENCYII,AEOI,SANCTIONS
REGULATORYCOMPLIANCE
REGULATORYCOMPLIANCE
SOLVENCYII,AEOI,SANCTIONS
PRIIPS,SOLVENCYII,AEOI,SANCTIONS
REGULATORYCOMPLIANCE
MIFIDII,PRIIPS,SOLVENCYII,AEOI,SANCTIONS
MIFIDII,PRIIPS,SOLVENCYII,AEOI,SANCTIONS
REGULATORYCOMPLIANCE
MIFIDII,PRIIPS,SOLVENCYII,AEOI,SANCTIONS
SOLVENCYII,AEOI,SANCTIONS
AEOI,SANCTIONS,MIFIDII,PRIIPS,SOLVENCYII
REGULATORYCOMPLIANCE
3.493.04 3.03 2.94
2.89 2.90 2.84
Mifid IIPriips FATCA Solvency II
SanctionsAEOI
FINFRAG
Figure 1: Which regulations are currently the top priorities for your firm?
Votes were cast using a scale of 1–5, where 1 denotes “not a priority” and 5 denotes a “top priority”
5Introduction
The implication of the current regulatory
environment is that firms are too
stretched to take the approach that would
be most beneficial from a strategic point
of view. Instead of having a consistent
approach to sourcing the data needed
for different regulations, different project
teams often approach multiple vendors
for what is sometimes the same data.
With various regulations affecting the
business simultaneously, this should
have presented an ideal opportunity for
firms to avoid this scenario by setting up
a common approach to data sourcing
to oversee regulatory activities and to
mitigate compliance risk and better
manage costs.
One of the challenges hindering firms
from taking a centralized approach when
ensuring compliance with new regulation
is existing data management practices.
Firms are heavily reliant on fragmented
data management processes, and the
lack of automation in the market is
making it difficult for firms to respond to
regulatory change efficiently. According
to the SIX survey, the majority are
working with at least partly—if not
entirely—manual processes, which are
likely to be resource-intensive and error-
prone (figure 2).
Figure 2: How is data managed and sourced at your firm?
When the backbone of the organization is
disintegrated, it is no surprise that many
firms source data for new regulation
at a divisional or regional level. Data is
inconsistently sourced and managed,
and firms are heavily reliant on disparate
data management processes. The risk,
however, is that regulatory reporting also
becomes fragmented, which puts firms at
risk of reporting different numbers where
there should have been consistency
across divisions or regions. This would
also make the introduction of regulations
counter-productive, as regulators are
ultimately introducing regulation to
protect investors and provide a safer and
more robust financial market.
Firms are heavily reliant on
fragmented data management
processes, and the lack of
automation in the market is making
it difficult for firms to respond to
regulatory change efficiently
45%
Automatic
35% Partly manual
16%
Manual
6
To address this, firms should consider
changing the internal architecture, as the
high volume of regulation is expected to
continue to affect financial services. In
particular, Mifid II, which expands Mifid
coverage to practically all asset classes,
meansahugegrowthinthevolumeofdata
that needs to be managed and reported
on. The extent of the data requirements
introduced under Mifid II means that
underlying data challenges, such as lack
of consistent and standardized processes,
are becoming more prominent. A siloed—
or partly siloed—approach is unlikely to
be sustainable in the long term as firms
grapple with the mammoth task of Mifid
II reporting. The significantly expanded
reach of Mifid II will make the challenge
to ensure consistency and quality in
the reporting is more prominent than in
previous years, and thus the starting point
needs to be creating a more harmonized
data management structure.
Figure 3: Who is responsible for—or has closest
responsibility for—regulatory compliance and
data demands within your organization?
To achieve improved centralization in any
organization, the organizational structure
also needs to adapt. At the moment,
this appears to be a key challenge for
financial services firms striving to meet
regulatory deadlines. The SIX survey
reveals that IT, operations, legal and
compliance, and risk management are all
seen to be responsible for both regulatory
compliance and data demands affecting
the business in close to 40 percent of
firms. This indicates that a large number
of stakeholders are involved, and different
teams with different mandates are likely
to be responsible for signing off on
regulatory compliance (figure 3).
With more business units
responsible for regulatory
compliance, the risk could
be that no business unit
is solely accountable for
ensuring compliance
Introduction
Traditionally, introducing changes to
adhere to new regulatory requirements
may have come mainly under legal
and compliance, but the market is
now seeing even risk management
taking on a significant role in signing
off on regulatory compliance. With more
business units responsible for regulatory
compliance, the risk could be that no
business unit is solely accountable for
ensuring compliance.
IT
?
37%
OPERATIONS
39%
LEGAL & COMPLIANCE
54%
35%
9%
RISK MANAGEMENT
OTHER
7
The additional involvement from different
business units can also contribute to
a more siloed approach. To avoid
fragmentation and different units
working on separate parts of regulatory
compliance, firms will need to consider
defining a common approach to
regulatory compliance, as well as
providing each unit with access to a
common set of data. The business must
be more engaged to be able to define
company-wide requirements, and then
set a strategy to enable the firm to meet
those requirements.
The strategy so far has often been based
on adding more staff. However, the SIX
survey shows that the majority of firms
now feel the head count is not an issue
for staying on top of compliance. More
than 60 percent said they have sufficient
head count, but instead, many said it is
increased automation that would help
enhance quality and/or timely handling
(figure 4).
Since the majority do not view regulation
as a head-count problem, it could
suggest that firms have added resources
to deal with imminent compliance
challenges instead of making the most
of the regulatory era and future-proofing
systems and processes. The significant
investments made to comply with Mifid
II and other regulations could most
likely have justified a complete rethink
of how to manage people, processes
and systems, but some firms may
instead be making do with a fragmented
landscape of outdated legacy systems,
working around the shortcomings by
adding manual resources. The risk is
that a sudden increase in the scale and
volume of regulatory demands will put
unbearable pressure on institutions that
have failed to modernize the internal
supply chain to ensure it is fit for the new
fast-changing regulatory environment.
By getting past the strategy of adding
manual resources and focusing on
getting the foundation right, firms are
likely to be able to improve efficiencies
and lower operational costs. Instead of
starting from scratch—identifying data
points, sourcing the data, cleansing the
data, and then creating and applying
rule sets—firms have the opportunity
to work with partners and vendors that
can offer value-adding services such
Figure 4: Do you have sufficient head count
to stay on top of compliance?
as pre-packaged datasets. To source
and cleanse data for new regulation
without leveraging a vendor service
can be a huge headache when there is
no reliable, central data management
system, particularly since firms are under
immense pressure to prepare for a whole
wave of new regulations.
With this in mind, SIX has introduced
a range of pre-packaged services
that goes beyond simply delivering
a data feed, but rather provides the
right data points, complete with
automatic flagging applied for Mifid II.
The services—helping firms with the
common reporting standard, Mifid II and
sanctions—are out-of-the-box offerings,
meaning customers can simply plug
and play.
The risk is that a sudden
increase in the scale and
volume of regulatory demands
will put unbearable pressure
on institutions that have failed
to modernize the internal
supply chain
Introduction
YES
19.2%
18.9%
43.2%
18.7%
NO
81.3%
NEED A GREATER AUTOM
A
TION
NEED GREATER HEAD
COUNT
8
For firms dealing with an array of new
requirements that have arrived or are on
the horizon, it is clear that budgets and
resources have been pushed to their
limits. In some cases, firms are not even
fully aware of how regulations may affect
them, and in other cases firms may have
anticipated deadlines being pushed back,
since there has been a trend of regulatory
deadlines being postponed in previous
years.
Regulatory deadlines, however, are real
and fast approaching and, based on
the outcome of the SIX survey, market
participants have no time to waste. The
survey revealed that only around one-third
had systems and data in place for Mifid II
as the regulatory deadline approached —
a percentage that should have been much
higher had firms allocated sufficient time
for testing prior to the go-live date.
In terms of Priips, the survey also
highlighted that many firms may struggle
to prepare in a timely fashion, as fewer
than 20 percent of respondents said
they had systems and data in place
ready for regulatory deadlines. This
is despite the fact that regulation has
been around longer, and the significant
overlap between the data in Priips key
information documents (KIDs) and the
data needed for Mifid II (figure 5).
If firms had taken a common data-
sourcing approach to preparing for new
regulation, Mifid II and Priips should
have created the perfect opportunity
for firms to work strategically, avoiding
a duplication of work and data costs by
identifying synergies and ensuring there
Ready, set, go
If firms had taken a common data sourcing approach to
preparing for new regulation, Mifid II and Priips should have
created the perfect opportunity for firms to work strategically,
avoiding a duplication of work and data costs
is a common data source that feeds both
Priips-KIDs and Mifid II reporting. By
not looking at these two regulations in
context, firms risk sending out different
numbers to investors in Mifid II cost
sheets and Priips-KIDs, or failing to
ensure the time displayed in a PDF format
in the Priips-KID matches the timestamp
reflected in the Mifid II reporting for
the transaction. To get this right and
comply with both regulations, it is vital
for firms to align the metadata and data
connectivity, which can then help ensure
synchronization. This need is most
pressing for firms with sophisticated or
complicated products, whose dynamic,
fast-changing nature is most likely
to suffer if errors are created in the
reporting. If the numbers do not add up,
fragmented architecture and inconsistent
data could ultimately end up undermining
the regulation and putting the firm at risk
of being targeted for class action lawsuits
from investors.
Considering the low level of readiness
for upcoming regulation, it would appear
that firms are racing against time to
get compliance programs moving.
Companies stuck at the analysis stage
should start reassessing the viability of
doing everything in-house and review
what is available off-the-shelf, as many
business-ready solutions on the market
could be better options for ensuring
compliance by the deadline. Now is the
time to start leaning on vendors and data
specialists for templates, datasets and
ready-packaged services, which could
help shorten the time it could take to
prepare for new regulation.
Ready, set, go
9
The concern is that, as the wave of
regulations reaches a crescendo, firms
are doing the bare minimum to comply
with and solve the regulatory challenges
by increasing head count. Despite the lack
of system readiness reported for various
regulations, firms are still optimistic that
the regulatory deadlines are within reach,
which indicates strategic planning is
limited. In the survey, 61.7 percent said
they think they will be able to meet the
deadline with the existing head count,
processes and architecture (figure 6).
The questions is, to what extent and how
efficiently? The inclusion of Solvency
II, which has already been introduced,
suggests that some firms may have gone
back to the drawing board to rethink their
compliance after having met the original
deadline. Are firms in danger of that
happening again with Mifid and Priips?
Ready, set, go
Are you ready for the regulation?
MIFID II - 35.5%
YES - 61.7%
NO - 13.9%
DON’T KNOW - 24.3%
PRIIPS - 18.4%
FATCA - 37.5%
SOLVENCY II - 28.2%
SANCTIONS - 33.3%
AEOI - 9.8%
FINFRAG - 12.7%
Will you be ready?
0100
0 100
Readiness will be ensured -
but at what price?
Figure 5: How ready are your firm’s data and systems for
compliance with these regulations?
Figure 6: Are you able to meet the regulatory requirements with current
head count, processes and architecture?
10
As non-compliance is associated with
potential regulatory fines and reputational
damage, it is not surprising that the
majority of firms are confident that they
will make it happen. However, when it
comes to firms who are only focused
on being technically compliant by any
specific regulatory deadline, regulatory
preparations are likely to have been
focused on short-term fixes instead
of strategic solutions. As pressure on
systems grows over the coming years, a
short-term fix based on a sizeable head-
count spend could come under pressure,
and firms would then recognize the need
to get the foundation right to ensure
quality and consistency in data feeding
regulatory reports.
According to the SIX survey, only 27
percent of firms source and cleanse data
centrally and distribute data consistently
when preparing for new regulations.
Instead, 30.4 percent of firms said
regulations are addressed separately with
their own data and data management
systems, and for 40.9 percent of firms
data is most often sourced separately
to address regulatory requirements. But
there are also instances where needs are
addressed by a central system (figure 7).
Breaking down the silos
The survey highlights that few are taking
an enterprise-wide view, or are looking at
regulations strategically, meaning firms
are not necessarily making the most of the
investments made to become compliant.
The main reason for this, according to
the SIX survey, is the tight regulatory
deadlines. The survey revealed that
deadlines are seen as the most important
reason preventing or hindering firms
from taking a strategic approach to
new regulation, and the second most
important reason is the challenge of
having different departments and data
acquisition teams working in silos
across different regulations. (figure 8 -
see appendix).
Because of the problems related to
breaking down silos, firms may be
missing overlapping data points in
different regulations, and so they end up
duplicating data sourcing and cleansing
efforts. There are numerous examples
of synergies—for example in the Priips
regulatory technical standards—that
explicitly mention Mifid II complexity
definitions as the basis for comprehension
alerts. Since Priips products are also sold
under Mifid II rules, having an enterprise-
wide approach to data allows firms to
be better placed for compliance as well
as cut costs by sourcing data once and
using it many times in the different levels
of detail required under Priips and Mifid II.
Breaking down the silos
Deadlines, followed by the challenge of having different
departments and data acquisition teams working in silos
across different regulations are the biggest obstacles
to a strategic approach to new regulation.
11
Figure 7: What approach does your organization typically take when preparing for new regulation?
Breaking down the silos
ALWAYS OR MOSTLY
SOURCE DATA
SEPARATELY
PER REGULATION
DATA IS SOURCED
CLEANSED AND
DISTRIBUTED
CONSISTENTLY
COMPLIANCEREPORTINGTRADINGRISK
Sanctions Priips Mifid IICRS IRS 871(m)
DATA MANAGEMENT
73% 27%
12 Breaking down the silos
Mifid II has highlighted the need
for firms to stop addressing
regulations in isolation, and
instead look at regulatory
compliance as a strategic
initiative across departments
and business units
The survey highlights that achieving
compliance is very difficult for every firm,
and the more firms can look to partners
and select vendors strategically, the more
they can cut costs and start focusing on
differentiating business activities instead
of becoming compliance experts.
For SIX, the aim is to make it easy for
the industry to share data and distribute
it. The vendor acquires data from 1,500
data sources, normalizes it and makes it
easy to consume. To help firms prepare
for new regulation, SIX has analyzed the
regulatory requirements and created
pre-packaged services that can help
customers become compliant and
avoid buying the same data multiple
times. Without this approach, firms risk
unintentionally stockpiling a surplus of
discarded data, the financial services
equivalent of the EU’s notorious ‘butter
mountains’ that have become tabloid
shorthand for wasteful consumption.
Considering the current state of the
market, there should be significant
opportunities for firms to leverage data
providers and infrastructure partners, and
reduce costs by removing duplication
and data redundancy. In fact, more than
70 percent of respondents agreed that
there could be more opportunities for
coordinating regulatory projects and
defining synergies between regulations
affecting the business.
Right now, firms are beginning to realize
the imminent need to achieve better
coordination when it comes to regulatory
preparations, and the work that has gone
into preparing for Mifid II across divisions
could potentially trigger a change in
the approach firms take when next
implementing new regulation. Mifid II
has highlighted the need for firms to stop
addressing regulations in isolation, and
instead look at regulatory compliance as
a strategic initiative across departments
and business units. Untangling the
regulatory spaghetti will require a
fundamental rethink, but at some point
it will be the only viable way forward for
firms that want to remain competitive as
regulatory pressure remains and margins
continue to be squeezed.
In the eyes of the regulators, consistency
is key, and to ensure consistency it is vital
to ensure the organization has a single
version of the truth—not multiple truths for
different regulations. By failing to recognize
the synergies between data points required
under different regulations, firms could be
introducing increased systemic risk into their
systems, and vendors with pre-packaged
datasets could play a key role in helping firms
overcome this challenge.
13Breaking down the silos
Figure 9: Could there be more opportunities for coordinating regulatory projects and defining synergies between regulations
affecting the business?
COMPLIANCEREPORTINGTRADINGRISK
Business
application
integration
CRS
FATCA
IRS
871(m)
PriipsMifid II
Solvency II
Sanctions
YES NO
71% 21% 8%
Reference
data &
corporate
actions
DON’T
KNOW
14
Conclusion
The financial services market is faced with
a fast-changing regulatory environment,
and there continues to be numerous
deadlines to hit for initiatives that are
introducingoftenmajorchangestoexisting
processes. The new environment calls for
firms to reassess existing strategies for
dealing with new regulation, as processes
need to be updated to account for the pace
of change. There is an immediate need for
firms to break down silos, and ensure the
organization has an enterprise-wide view
of data and approach to implementation.
By missing the synergies between
different regulations, firms are introducing
increased risk into their processes and
could still be subject to regulatory fines
despite being under the impression that
deadlines have been met. Consistency
and quality is key—not only to regulators
but also to investors—and the only way to
ensure numbers are the same in different
regulatory reports is to ensure the firm has
a single version of the truth.
In the rush to get ready, many firms may
have piled on extra head counts – an easy
target for efficiency savings once the
deadline has been and gone. But what
may be escaping their attention is that
reducing the festering heap of duplicate
data could be one of the fastest ways to
gain efficiency savings in the long term.
Despite the mess many firms find
themselves in right now, data vendors can
help untangle the regulatory spaghetti by
delivering templates, datasets and ready-
packaged data and services. Forward-
thinking firms will use the regulatory wave
toassesshowtoavoidbuildingtomorrow’s
cumbersome legacy systems today and
start looking for scalable systems that can
enable automation to meet ever-changing
business requirements.
Now is the time for firms to stop browsing and start
shopping.
Forward-thinking firms will
use the regulatory wave to
assess how to avoid building
tomorrow’s cumbersome legacy
systems today and start looking
for scalable systems that can
enable automation
Conclusion
MULTIPLE DATA POINTS
INEFFICIENT USE OF DATA
HIGH COSTS
SINGLE DATA POINT
EFFICIENT USE OF DATA
LONG-TERM SAVING
15
Appendix
Mifid II 3.49
Priips 2.84
Fatca 3.04
Solvency II 2.90
Sanctions 3.03
Automatic Exchange of Information (AEOI) 2.94
Financial Markets Infrastructure Act (FinfraG) 2.89
Yes 61.7%
No 13.9%
Don’t know 24.3%
Yes 70.6%
No 8.3%
Don’t know 21.1%
Requirments
gathering
Vendor
selection
Systems and data in
place/ integrated
Mifid II 29.1% 7.3% 35.5%
Priips 13.6% 10.7% 18.4%
Fatca 16.3% 4.8% 37.5%
Solvency II 16.5% 6.8% 28.2%
Sanctions 9.5% 5.7% 33.3%
AEOI 8.8% 9.8% 9.8%
FinfraG 10.8% 4./9% 12.7%
Automatically on a divisional level with different
systems and processes
7.4%
Automatically on a regional level with different systems
and processes
13.5%
Automatically enterprise-wide with common systems
and processes
25.0%
Partly manually and partly through automated
processes
35.1%
Manually on a divisional level with different systems
and processes
7.4%
Manually enterprise-wide with common systems and
processes
4.1%
Manually on a regional level with different systems
and processes
4.7%
Other 2.7%
IT 37.2%
Operations 38.5%
Legal and compliance 54.1%
Risk management 35.1%
Other 8.8%
Regulations are addressed separately with their own
data and data management systems
30.4%
Data is most often sourced separately to address regu-
latory requirements, but there are also instances where
needs are addressed by a central system
40.9%
Data is sourced, cleansed centrally and distributed
consistently across all regulations
27.0%
Other 1.7%
Limited budgets for meeting the wave of new regulatory
requirements
3.33
Tight regulatory deadlines 3.46
Different departments/data acquisition teams working
in silos across different regulations
3.38
Outdated legacy systems or disparate internal systems 3.34
Internal challenges relating to governance and
decision-making
3.16
Other 3.02
We don’t have sufficient head count, and improved
automation would help solve the problem
19.6%
We don’t have sufficient head count 18.9%
We have sufficient head count, but automated systems
would help enhance quality and/or timely handling
43.2%
We have sufficient head count and have no problem
with quality and time
18.2%
Figure 1: Which regulations are currently the top priorities
at your firm?
Figure 5: How ready are your firm’s data and systems for
compliance with these regulations?
Figure 6: Are you able to meet the regulatory requirements
with current head count, processes and architecture?
Figure 9: Could there be more opportunities for coordinating
regulatory projects and defining synergies between
regulations affecting the business?
Figure 2: How is data managed and sourced at your firm?
Figure 3: Who is responsible for—or has closest responsibility
for - regulatory compliance and data demands within your
organization?
Figure 7: What approach does your organization typically take
when preparing for new regulation?
Figure 8: What hinders the firm from taking a strategic approach
to new regulation?
Figure 4: Do you have sufficient head count to stay on top
of compliance?
Statistics quoted from a survey of 110 financial institutions carried out on behalf of SIX.
Appendix
BUSINESS
APPLICATION
INTEGRATION
COMPLIANCE
REPORTING
TRADING
RISK
BUSINESS
APPLICATION
INTEGRATION
COMPLIANCE
REPORTING
TRADING
RISK
BUSINESS
APPLICATION
INTEGRATION
www.six-group.com

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Navigating Regulatory Spaghetti with Data Management

  • 1. BUSINESS APPLICATION INTEGRATION COMPLIANCE REPORTING TRADING RISK BUSINESS APPLICATION INTEGRATION Time to untangle the regulatory spaghetti - Avoiding the minimum viable compliance trap with new approaches to data management
  • 2.
  • 3. 3Executive summary Executive summary COMPLIANCE CROSSROADS TACTICAL AND READY NOW STRATEGIC AND READY FOR THE LONG-TERM Are you set up to identify synergies within the current regulatory data and system requirements? As firms continue to be hit with new regulations, the pressure is on to navigate the maze of new data requirements. Firms no longer have the luxury of tackling one piece of regulation at a time, and the wave taking the market by storm appears to be never-ending. In fact, the focus on improving automation and streamlining processes appears to come second as firms now strive to hit fast-approaching deadlines. The project teams tasked with making the necessary changes to ensure a firm is compliant are typically focused on a single specific regulation and then simply source the data and systems to solve that problem. With this approach, firms fail to identify overlapping data points and risk potentially reporting on different numbers in different regulatory reports. Still, few are concerned about data duplication and siloed approaches and, despite not having systems in place months before a regulatory go-live date, there is confidence in the market that becoming compliant is achievable. The worry is that, when the aim is to hit a regulatory deadline and avoid fines, doing the bare minimum to comply does not fit in with strategic planning and long-term operational goals. This regulation-intensive environment means firms have two options—to continue to add more head count and implement tactical systems and processes to comply with new requirements, or to identify ways to work across project teams and find ready-made services that can be implemented quickly and to acquire regulatory data more efficiently. The latter option is the direction in which the majority sees the market headed and, according to a SIX survey, more than 70 percent feel there could be more opportunities for coordinating regulatory projects and defining synergies between regulations affecting the business. The survey revealed that firms continue to operate in a siloed environment and lack the ability to take an enterprise-wide view of regulation, which could hinder firms in hitting regulatory deadlines and ensuring reports are underpinned by quality data. The reality is that the market is overwhelmed by the amount of regulation affecting business, and the main method of dealing with regulation is still to increase head count. Increased head count, however, does not necessarily help firms ensure robust data quality, and having more personnel managing data may be affecting data quality rates as increased manual intervention further hinders automation.
  • 4. 4 Introduction One of the basic principles of construction is to build walls before erecting the roof— unless it is about putting up a temporary cover to protect the building site in a rainstorm. When it comes to regulatory compliance it seems as if firms easily forget to build their walls before the roof—or they simply make do with a temporary rain cover. In many cases, the ‘building foundation’ seems to have been forgotten as firms become overwhelmed by the wave of regulation and lose focus. In the past, firms had more time to focus on each major new directive, as there were fewer regulatory deadlines to meet in the same year. Now, many organizations will be dealing with everything from Europe’s second Markets in Financial Instruments Directive (Mifid II) and Packaged Retail and Insurance-based Investment Products regulation (Priips), and the US’s Foreign Account Tax Compliance Act (Fatca) to Switzerland’s Automatic Exchange of Information (AEOI) and Financial Markets Infrastructure Act (FinfraG) all at the same time. Considering the trend of multiple regulatory deadlines arriving on a similar time horizon, it is not surprising that many organizations are showing signs of “compliance fatigue”. Introduction According to an exclusive SIX survey of more than 100 senior industry professionals representing buy-side and sell-side firms, respondents found it difficult to identify which regulation was currently the most important for their organization to address. The result suggests that most firms are trying to fight fires on all fronts to keep on top of compliance obligations as non- compliance is not an option (figure 1). MIFIDII,PRIIPS,SOLVENCYII AEOI,SANCTIONS REGULATORYCOMPLIANCE REGULATORYCOMPLIANCE REGULATORYCOMPLIANCE PRIIPS,SOLVENCYII,AEOI,SANCTIONS REGULATORYCOMPLIANCE REGULATORYCOMPLIANCE SOLVENCYII,AEOI,SANCTIONS PRIIPS,SOLVENCYII,AEOI,SANCTIONS REGULATORYCOMPLIANCE MIFIDII,PRIIPS,SOLVENCYII,AEOI,SANCTIONS MIFIDII,PRIIPS,SOLVENCYII,AEOI,SANCTIONS REGULATORYCOMPLIANCE MIFIDII,PRIIPS,SOLVENCYII,AEOI,SANCTIONS SOLVENCYII,AEOI,SANCTIONS AEOI,SANCTIONS,MIFIDII,PRIIPS,SOLVENCYII REGULATORYCOMPLIANCE 3.493.04 3.03 2.94 2.89 2.90 2.84 Mifid IIPriips FATCA Solvency II SanctionsAEOI FINFRAG Figure 1: Which regulations are currently the top priorities for your firm? Votes were cast using a scale of 1–5, where 1 denotes “not a priority” and 5 denotes a “top priority”
  • 5. 5Introduction The implication of the current regulatory environment is that firms are too stretched to take the approach that would be most beneficial from a strategic point of view. Instead of having a consistent approach to sourcing the data needed for different regulations, different project teams often approach multiple vendors for what is sometimes the same data. With various regulations affecting the business simultaneously, this should have presented an ideal opportunity for firms to avoid this scenario by setting up a common approach to data sourcing to oversee regulatory activities and to mitigate compliance risk and better manage costs. One of the challenges hindering firms from taking a centralized approach when ensuring compliance with new regulation is existing data management practices. Firms are heavily reliant on fragmented data management processes, and the lack of automation in the market is making it difficult for firms to respond to regulatory change efficiently. According to the SIX survey, the majority are working with at least partly—if not entirely—manual processes, which are likely to be resource-intensive and error- prone (figure 2). Figure 2: How is data managed and sourced at your firm? When the backbone of the organization is disintegrated, it is no surprise that many firms source data for new regulation at a divisional or regional level. Data is inconsistently sourced and managed, and firms are heavily reliant on disparate data management processes. The risk, however, is that regulatory reporting also becomes fragmented, which puts firms at risk of reporting different numbers where there should have been consistency across divisions or regions. This would also make the introduction of regulations counter-productive, as regulators are ultimately introducing regulation to protect investors and provide a safer and more robust financial market. Firms are heavily reliant on fragmented data management processes, and the lack of automation in the market is making it difficult for firms to respond to regulatory change efficiently 45% Automatic 35% Partly manual 16% Manual
  • 6. 6 To address this, firms should consider changing the internal architecture, as the high volume of regulation is expected to continue to affect financial services. In particular, Mifid II, which expands Mifid coverage to practically all asset classes, meansahugegrowthinthevolumeofdata that needs to be managed and reported on. The extent of the data requirements introduced under Mifid II means that underlying data challenges, such as lack of consistent and standardized processes, are becoming more prominent. A siloed— or partly siloed—approach is unlikely to be sustainable in the long term as firms grapple with the mammoth task of Mifid II reporting. The significantly expanded reach of Mifid II will make the challenge to ensure consistency and quality in the reporting is more prominent than in previous years, and thus the starting point needs to be creating a more harmonized data management structure. Figure 3: Who is responsible for—or has closest responsibility for—regulatory compliance and data demands within your organization? To achieve improved centralization in any organization, the organizational structure also needs to adapt. At the moment, this appears to be a key challenge for financial services firms striving to meet regulatory deadlines. The SIX survey reveals that IT, operations, legal and compliance, and risk management are all seen to be responsible for both regulatory compliance and data demands affecting the business in close to 40 percent of firms. This indicates that a large number of stakeholders are involved, and different teams with different mandates are likely to be responsible for signing off on regulatory compliance (figure 3). With more business units responsible for regulatory compliance, the risk could be that no business unit is solely accountable for ensuring compliance Introduction Traditionally, introducing changes to adhere to new regulatory requirements may have come mainly under legal and compliance, but the market is now seeing even risk management taking on a significant role in signing off on regulatory compliance. With more business units responsible for regulatory compliance, the risk could be that no business unit is solely accountable for ensuring compliance. IT ? 37% OPERATIONS 39% LEGAL & COMPLIANCE 54% 35% 9% RISK MANAGEMENT OTHER
  • 7. 7 The additional involvement from different business units can also contribute to a more siloed approach. To avoid fragmentation and different units working on separate parts of regulatory compliance, firms will need to consider defining a common approach to regulatory compliance, as well as providing each unit with access to a common set of data. The business must be more engaged to be able to define company-wide requirements, and then set a strategy to enable the firm to meet those requirements. The strategy so far has often been based on adding more staff. However, the SIX survey shows that the majority of firms now feel the head count is not an issue for staying on top of compliance. More than 60 percent said they have sufficient head count, but instead, many said it is increased automation that would help enhance quality and/or timely handling (figure 4). Since the majority do not view regulation as a head-count problem, it could suggest that firms have added resources to deal with imminent compliance challenges instead of making the most of the regulatory era and future-proofing systems and processes. The significant investments made to comply with Mifid II and other regulations could most likely have justified a complete rethink of how to manage people, processes and systems, but some firms may instead be making do with a fragmented landscape of outdated legacy systems, working around the shortcomings by adding manual resources. The risk is that a sudden increase in the scale and volume of regulatory demands will put unbearable pressure on institutions that have failed to modernize the internal supply chain to ensure it is fit for the new fast-changing regulatory environment. By getting past the strategy of adding manual resources and focusing on getting the foundation right, firms are likely to be able to improve efficiencies and lower operational costs. Instead of starting from scratch—identifying data points, sourcing the data, cleansing the data, and then creating and applying rule sets—firms have the opportunity to work with partners and vendors that can offer value-adding services such Figure 4: Do you have sufficient head count to stay on top of compliance? as pre-packaged datasets. To source and cleanse data for new regulation without leveraging a vendor service can be a huge headache when there is no reliable, central data management system, particularly since firms are under immense pressure to prepare for a whole wave of new regulations. With this in mind, SIX has introduced a range of pre-packaged services that goes beyond simply delivering a data feed, but rather provides the right data points, complete with automatic flagging applied for Mifid II. The services—helping firms with the common reporting standard, Mifid II and sanctions—are out-of-the-box offerings, meaning customers can simply plug and play. The risk is that a sudden increase in the scale and volume of regulatory demands will put unbearable pressure on institutions that have failed to modernize the internal supply chain Introduction YES 19.2% 18.9% 43.2% 18.7% NO 81.3% NEED A GREATER AUTOM A TION NEED GREATER HEAD COUNT
  • 8. 8 For firms dealing with an array of new requirements that have arrived or are on the horizon, it is clear that budgets and resources have been pushed to their limits. In some cases, firms are not even fully aware of how regulations may affect them, and in other cases firms may have anticipated deadlines being pushed back, since there has been a trend of regulatory deadlines being postponed in previous years. Regulatory deadlines, however, are real and fast approaching and, based on the outcome of the SIX survey, market participants have no time to waste. The survey revealed that only around one-third had systems and data in place for Mifid II as the regulatory deadline approached — a percentage that should have been much higher had firms allocated sufficient time for testing prior to the go-live date. In terms of Priips, the survey also highlighted that many firms may struggle to prepare in a timely fashion, as fewer than 20 percent of respondents said they had systems and data in place ready for regulatory deadlines. This is despite the fact that regulation has been around longer, and the significant overlap between the data in Priips key information documents (KIDs) and the data needed for Mifid II (figure 5). If firms had taken a common data- sourcing approach to preparing for new regulation, Mifid II and Priips should have created the perfect opportunity for firms to work strategically, avoiding a duplication of work and data costs by identifying synergies and ensuring there Ready, set, go If firms had taken a common data sourcing approach to preparing for new regulation, Mifid II and Priips should have created the perfect opportunity for firms to work strategically, avoiding a duplication of work and data costs is a common data source that feeds both Priips-KIDs and Mifid II reporting. By not looking at these two regulations in context, firms risk sending out different numbers to investors in Mifid II cost sheets and Priips-KIDs, or failing to ensure the time displayed in a PDF format in the Priips-KID matches the timestamp reflected in the Mifid II reporting for the transaction. To get this right and comply with both regulations, it is vital for firms to align the metadata and data connectivity, which can then help ensure synchronization. This need is most pressing for firms with sophisticated or complicated products, whose dynamic, fast-changing nature is most likely to suffer if errors are created in the reporting. If the numbers do not add up, fragmented architecture and inconsistent data could ultimately end up undermining the regulation and putting the firm at risk of being targeted for class action lawsuits from investors. Considering the low level of readiness for upcoming regulation, it would appear that firms are racing against time to get compliance programs moving. Companies stuck at the analysis stage should start reassessing the viability of doing everything in-house and review what is available off-the-shelf, as many business-ready solutions on the market could be better options for ensuring compliance by the deadline. Now is the time to start leaning on vendors and data specialists for templates, datasets and ready-packaged services, which could help shorten the time it could take to prepare for new regulation. Ready, set, go
  • 9. 9 The concern is that, as the wave of regulations reaches a crescendo, firms are doing the bare minimum to comply with and solve the regulatory challenges by increasing head count. Despite the lack of system readiness reported for various regulations, firms are still optimistic that the regulatory deadlines are within reach, which indicates strategic planning is limited. In the survey, 61.7 percent said they think they will be able to meet the deadline with the existing head count, processes and architecture (figure 6). The questions is, to what extent and how efficiently? The inclusion of Solvency II, which has already been introduced, suggests that some firms may have gone back to the drawing board to rethink their compliance after having met the original deadline. Are firms in danger of that happening again with Mifid and Priips? Ready, set, go Are you ready for the regulation? MIFID II - 35.5% YES - 61.7% NO - 13.9% DON’T KNOW - 24.3% PRIIPS - 18.4% FATCA - 37.5% SOLVENCY II - 28.2% SANCTIONS - 33.3% AEOI - 9.8% FINFRAG - 12.7% Will you be ready? 0100 0 100 Readiness will be ensured - but at what price? Figure 5: How ready are your firm’s data and systems for compliance with these regulations? Figure 6: Are you able to meet the regulatory requirements with current head count, processes and architecture?
  • 10. 10 As non-compliance is associated with potential regulatory fines and reputational damage, it is not surprising that the majority of firms are confident that they will make it happen. However, when it comes to firms who are only focused on being technically compliant by any specific regulatory deadline, regulatory preparations are likely to have been focused on short-term fixes instead of strategic solutions. As pressure on systems grows over the coming years, a short-term fix based on a sizeable head- count spend could come under pressure, and firms would then recognize the need to get the foundation right to ensure quality and consistency in data feeding regulatory reports. According to the SIX survey, only 27 percent of firms source and cleanse data centrally and distribute data consistently when preparing for new regulations. Instead, 30.4 percent of firms said regulations are addressed separately with their own data and data management systems, and for 40.9 percent of firms data is most often sourced separately to address regulatory requirements. But there are also instances where needs are addressed by a central system (figure 7). Breaking down the silos The survey highlights that few are taking an enterprise-wide view, or are looking at regulations strategically, meaning firms are not necessarily making the most of the investments made to become compliant. The main reason for this, according to the SIX survey, is the tight regulatory deadlines. The survey revealed that deadlines are seen as the most important reason preventing or hindering firms from taking a strategic approach to new regulation, and the second most important reason is the challenge of having different departments and data acquisition teams working in silos across different regulations. (figure 8 - see appendix). Because of the problems related to breaking down silos, firms may be missing overlapping data points in different regulations, and so they end up duplicating data sourcing and cleansing efforts. There are numerous examples of synergies—for example in the Priips regulatory technical standards—that explicitly mention Mifid II complexity definitions as the basis for comprehension alerts. Since Priips products are also sold under Mifid II rules, having an enterprise- wide approach to data allows firms to be better placed for compliance as well as cut costs by sourcing data once and using it many times in the different levels of detail required under Priips and Mifid II. Breaking down the silos Deadlines, followed by the challenge of having different departments and data acquisition teams working in silos across different regulations are the biggest obstacles to a strategic approach to new regulation.
  • 11. 11 Figure 7: What approach does your organization typically take when preparing for new regulation? Breaking down the silos ALWAYS OR MOSTLY SOURCE DATA SEPARATELY PER REGULATION DATA IS SOURCED CLEANSED AND DISTRIBUTED CONSISTENTLY COMPLIANCEREPORTINGTRADINGRISK Sanctions Priips Mifid IICRS IRS 871(m) DATA MANAGEMENT 73% 27%
  • 12. 12 Breaking down the silos Mifid II has highlighted the need for firms to stop addressing regulations in isolation, and instead look at regulatory compliance as a strategic initiative across departments and business units The survey highlights that achieving compliance is very difficult for every firm, and the more firms can look to partners and select vendors strategically, the more they can cut costs and start focusing on differentiating business activities instead of becoming compliance experts. For SIX, the aim is to make it easy for the industry to share data and distribute it. The vendor acquires data from 1,500 data sources, normalizes it and makes it easy to consume. To help firms prepare for new regulation, SIX has analyzed the regulatory requirements and created pre-packaged services that can help customers become compliant and avoid buying the same data multiple times. Without this approach, firms risk unintentionally stockpiling a surplus of discarded data, the financial services equivalent of the EU’s notorious ‘butter mountains’ that have become tabloid shorthand for wasteful consumption. Considering the current state of the market, there should be significant opportunities for firms to leverage data providers and infrastructure partners, and reduce costs by removing duplication and data redundancy. In fact, more than 70 percent of respondents agreed that there could be more opportunities for coordinating regulatory projects and defining synergies between regulations affecting the business. Right now, firms are beginning to realize the imminent need to achieve better coordination when it comes to regulatory preparations, and the work that has gone into preparing for Mifid II across divisions could potentially trigger a change in the approach firms take when next implementing new regulation. Mifid II has highlighted the need for firms to stop addressing regulations in isolation, and instead look at regulatory compliance as a strategic initiative across departments and business units. Untangling the regulatory spaghetti will require a fundamental rethink, but at some point it will be the only viable way forward for firms that want to remain competitive as regulatory pressure remains and margins continue to be squeezed. In the eyes of the regulators, consistency is key, and to ensure consistency it is vital to ensure the organization has a single version of the truth—not multiple truths for different regulations. By failing to recognize the synergies between data points required under different regulations, firms could be introducing increased systemic risk into their systems, and vendors with pre-packaged datasets could play a key role in helping firms overcome this challenge.
  • 13. 13Breaking down the silos Figure 9: Could there be more opportunities for coordinating regulatory projects and defining synergies between regulations affecting the business? COMPLIANCEREPORTINGTRADINGRISK Business application integration CRS FATCA IRS 871(m) PriipsMifid II Solvency II Sanctions YES NO 71% 21% 8% Reference data & corporate actions DON’T KNOW
  • 14. 14 Conclusion The financial services market is faced with a fast-changing regulatory environment, and there continues to be numerous deadlines to hit for initiatives that are introducingoftenmajorchangestoexisting processes. The new environment calls for firms to reassess existing strategies for dealing with new regulation, as processes need to be updated to account for the pace of change. There is an immediate need for firms to break down silos, and ensure the organization has an enterprise-wide view of data and approach to implementation. By missing the synergies between different regulations, firms are introducing increased risk into their processes and could still be subject to regulatory fines despite being under the impression that deadlines have been met. Consistency and quality is key—not only to regulators but also to investors—and the only way to ensure numbers are the same in different regulatory reports is to ensure the firm has a single version of the truth. In the rush to get ready, many firms may have piled on extra head counts – an easy target for efficiency savings once the deadline has been and gone. But what may be escaping their attention is that reducing the festering heap of duplicate data could be one of the fastest ways to gain efficiency savings in the long term. Despite the mess many firms find themselves in right now, data vendors can help untangle the regulatory spaghetti by delivering templates, datasets and ready- packaged data and services. Forward- thinking firms will use the regulatory wave toassesshowtoavoidbuildingtomorrow’s cumbersome legacy systems today and start looking for scalable systems that can enable automation to meet ever-changing business requirements. Now is the time for firms to stop browsing and start shopping. Forward-thinking firms will use the regulatory wave to assess how to avoid building tomorrow’s cumbersome legacy systems today and start looking for scalable systems that can enable automation Conclusion MULTIPLE DATA POINTS INEFFICIENT USE OF DATA HIGH COSTS SINGLE DATA POINT EFFICIENT USE OF DATA LONG-TERM SAVING
  • 15. 15 Appendix Mifid II 3.49 Priips 2.84 Fatca 3.04 Solvency II 2.90 Sanctions 3.03 Automatic Exchange of Information (AEOI) 2.94 Financial Markets Infrastructure Act (FinfraG) 2.89 Yes 61.7% No 13.9% Don’t know 24.3% Yes 70.6% No 8.3% Don’t know 21.1% Requirments gathering Vendor selection Systems and data in place/ integrated Mifid II 29.1% 7.3% 35.5% Priips 13.6% 10.7% 18.4% Fatca 16.3% 4.8% 37.5% Solvency II 16.5% 6.8% 28.2% Sanctions 9.5% 5.7% 33.3% AEOI 8.8% 9.8% 9.8% FinfraG 10.8% 4./9% 12.7% Automatically on a divisional level with different systems and processes 7.4% Automatically on a regional level with different systems and processes 13.5% Automatically enterprise-wide with common systems and processes 25.0% Partly manually and partly through automated processes 35.1% Manually on a divisional level with different systems and processes 7.4% Manually enterprise-wide with common systems and processes 4.1% Manually on a regional level with different systems and processes 4.7% Other 2.7% IT 37.2% Operations 38.5% Legal and compliance 54.1% Risk management 35.1% Other 8.8% Regulations are addressed separately with their own data and data management systems 30.4% Data is most often sourced separately to address regu- latory requirements, but there are also instances where needs are addressed by a central system 40.9% Data is sourced, cleansed centrally and distributed consistently across all regulations 27.0% Other 1.7% Limited budgets for meeting the wave of new regulatory requirements 3.33 Tight regulatory deadlines 3.46 Different departments/data acquisition teams working in silos across different regulations 3.38 Outdated legacy systems or disparate internal systems 3.34 Internal challenges relating to governance and decision-making 3.16 Other 3.02 We don’t have sufficient head count, and improved automation would help solve the problem 19.6% We don’t have sufficient head count 18.9% We have sufficient head count, but automated systems would help enhance quality and/or timely handling 43.2% We have sufficient head count and have no problem with quality and time 18.2% Figure 1: Which regulations are currently the top priorities at your firm? Figure 5: How ready are your firm’s data and systems for compliance with these regulations? Figure 6: Are you able to meet the regulatory requirements with current head count, processes and architecture? Figure 9: Could there be more opportunities for coordinating regulatory projects and defining synergies between regulations affecting the business? Figure 2: How is data managed and sourced at your firm? Figure 3: Who is responsible for—or has closest responsibility for - regulatory compliance and data demands within your organization? Figure 7: What approach does your organization typically take when preparing for new regulation? Figure 8: What hinders the firm from taking a strategic approach to new regulation? Figure 4: Do you have sufficient head count to stay on top of compliance? Statistics quoted from a survey of 110 financial institutions carried out on behalf of SIX. Appendix