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Monday, February 15, 2016

The Beauty of BCBS 239

BCBS 239 is the commonly-referenced name of a publication released in January 2013 by the Basel Committee on Banking Supervision (a committee of the BIS, or Bank for International Settlements). Its full title is "Principles for effective risk data aggregation and risk reporting".

The publication, which is 28 pages long is available here:
http://www.bis.org/publ/bcbs239.pdf

If you work in a large bank and are not familiar with BCBS 239, it may behoove you to read it.  If you work in risk management, data warehousing or compliance, you're probably already familiar with it.   But if you work in the back office, middle office, or a business line and are struggling with the challenge of unavailable, incomplete, or undocumented data, BCBS 239 can be an important tool in getting your requests taken seriously by your institution's executive management, or data management and IT bureaucracy.

Who wrote BCBS 239?
BCBS 239 was written by a committee of representatives from the financial regulators in 13 countries.  That includes the FRB and OCC in the US, the FSA in UK, and the JFSA and BOJ in Japan.  If you work in a large financial institution, you probably already know the influence these groups have over the project portfolio and purse-strings of your bank.

What does BCBS 239 say?
BCBS 239 lays out 14 principles about risk data, summarized in 4 groups, and further subdivided into 89 paragraphs.  There is a summary of the principles in annex 2 of the document.  But I found that some of the most interesting and useful language is in the detail itself.

BCBS 239 is surprisingly direct in saying what many line-level practitioners have been saying and thinking for years: it shouldn't be so damned hard to get the information I need from my bank's systems on a daily basis.  And I should be able to depend on the accuracy and completeness of that information.  Unfortunately, in today's world of split-second searches over billions of websites and self-driving cars, that is not the reality in most large financial institutions.

BCBS spells out principles that should be no-brainers.  But they are often not followed today.  It's good that the authorities have spelled them out, so that they can be used as ammunition by business users who actually need good data to get a job done.

Here are some of my favorite "no-brainers" that I'm glad to see confirmed by the committee:

  • "Controls surrounding risk data should be as robust as those applicable to accounting data."(Principle 3 Accuracy and Integrity, paragraph 36a).  
  • "Risk data should be reconciled with bank's sources, including accounting data where appropriate, to ensure that the risk data is accurate." (Principle 3 Accuracy and Integrity, paragraph 36c).
  • "Supervisors expect banks' data to be materially complete, with any exceptions identified and explained." (Principle 4 Completeness, paragraph 43).
To me this means a bank must allocate and hold accountable actual staff to make sure the data in the data warehouse is correct and reconciled.  Plenty of staff.  Think how many people are dedicated to making sure the accounting data is correct: Comptrollers, Sarbanes-Oxley compliance people, internal auditors, etc.  And the "risk data" is arguably more varied and complex than accounting data.
  • "A bank should establish integrated data taxonomies and architecture across the banking group...."  (Principle 2 Data architecture and IT infrastructure, paragraph 33)
  • "A bank should develop an inventory and classification of risk data items which includes a reference to the concepts used to elaborate the reports." (Principle 9 Clarity & Usefulness, paragraph 67)
In other words, the data in the warehouse needs to be well-organized and documented--not just a mish-mash of incompatible records from different source systems.
  • Principle 6 Adaptability – A bank should be able to generate aggregate risk data to meet a broad range of on-demand, ad hoc risk management reporting requests, including requests during stress/crisis situations, requests due to changing internal needs and requests to meet supervisory queries.
  • "A bank should routinely test its ability to produce accurate reports within established timeframes, particularly in a stress/crisis situation." (Principle 10, Frequency, paragraph 70)
  • "Some position / exposure information may be needed immediately (intraday)...." (Principle 10, Frequency, paragraph 70)

In other words, it's not acceptable for IT to demand a project and special budget just to produce some reports for the business.  The data must be available and usable in advance.

Conclusion
For years, those of us who work on the ground in financial institutions have heard statements from data practitioners about the strategic importance of data, and read vague statements of policy and principle from our data and IT organizations.  But at the same time the actual data we see is often incomplete, poorly organized, or inaccurate, and the day to day tasks needed to clean up the mess are never prioritized.

BCBS 239 is a clear and straightforward document that tells G-SIBs and other financial institutions to actually use 21st century technology to deliver practical results.  While it may be a challenge to implement at most banks, it is a challenge whose time has come.

Tuesday, October 02, 2012

Making it Look Easy: How Warren Buffett Did It

Article: The Economist, The Secrets of Buffett's Success

Interesting article in this week's Economist about a study of how Warren Buffett has managed to make such successful investments over a long period of time, and stock-picking has very little to do with it.  It comes down to two simple factors:

1) He concentrates on stocks with low betas (ie, low risk, low return stocks).  According to the article, these stocks perform better on a risk-adjusted basis than high flying stocks. (Possibly, I guess, because investors who are looking to get rich quick overlook them, so they are in less demand.)

2) He leverages his portfolio (ie, borrows money to buy more stock).  His source of funds is not loans or bonds, but insurance premiums, which gives him an extremely low funding cost.

This makes a lot of sense, especially if you read Buffett's annual shareholder letter, which always describes with glee the free float he gets from his insurance businesses.  (Letters are available here, and well worth reading).

Now that I know the secret, I just have to get hold of a massively successful insurance company.

Saturday, September 01, 2012

Obama's Economics Report Card

Article: The Economist, Barack Obama's Economic Record

Well worth reading.



Sunday, August 19, 2012

The Quandary of Air Conditioning

Article: New York Times, The Cost of Cool by Elisabeth Rosenthal

Here's another vicious circle for you: as the populations of tropical developing nations move into the middle class, they will demand air conditioned homes, offices and cars, just like Americans do.  This will  contribute to global warming, which will further increase the demand for air conditioning, until... What?

Elisabeth Rosenthal's article is informative and thought-provoking.  It does not simply bash our decadent comfort-seeking life-style, but notes that air conditioning brings benefits for our health and productivity, and seems to be a requirement for modern knowledge workers, especially in hot climates.  This is a quandary, for which there is no simple obvious solution.

One more thing to puzzle and worry about...

http://graphics8.nytimes.com/images/2012/08/19/opinion/19rosenthal_chart/19rosenthal_chart-custom1.png

Sunday, July 29, 2012

World Jewish Population

Very interesting special special report in this week's Economist on Judaism and the Jews, including the graphic below.  The total Jewish world population of 13.6 million is similar to that of the country of Zambia, or the city of Karachi, Pakistan.

from The Economist magazine www.economist.com

Saturday, February 25, 2012

Is There Life After Fifty?

Article: The Economist, Schumpeter, Enterprising Oldies

This article, which is short and well worth reading gave me some hope.  Zuckerberg and company aside, it gives a bunch of examples and reasons why entrepreneurship and other creative endeavors are not only for the young-- not by a long shot.  For example:

  • Dane Stangler of the Kauffman Foundation found that highest rate of entrepreneurial activity was in the 55-64 age group.  Lowest was in the 20-34 age group.
  • Ray Croc started McDonald's in his 50's.
  • Colonel Harland Sanders started KFC in his 60's.
  • The Stones, Dylan, Paul McCartney, Leonard Cohen: still going strong.
  • Arianna Huffington founded the Huffington Post at age 54.
  • Marc Pincus founded Zynga at age 41.

Tuesday, February 07, 2012

Six Latin American Countries Without Ambassadors

Article: U.S. Sway Clipped In Latin America, Nicolas Casey, Wall Street Journal

Can you name the six Latin American countries whose ambassadorial appointments have been held up in Congress?  They are:
  • Barbados
  • Ecuador
  • El Salvador
  • Nicaragua
  • Urugay
  • Venezuela
Article also has a nice map...