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Confidential Copyright © 2015 EDM Council Inc.
Page 1
Data Management Capabilities
Assessment Model
(DCAM)
Confidential Copyright © 2015 EDM Council Inc.
Page 2
• 2008 Crisis: Inability to model contagion
(who finances who, who is linked to who,
what are the obligations of complex
financial instruments)
• Senior Banking Supervisors Group:
Observations on Developments in Risk
Appetite Frameworks and IT Infrastructure
(intractable relationship between data and
risk management and definition of control
environment)
• BCBS 239: Principles of Risk Data
Aggregation and Reporting (governance,
content infrastructure and data quality as
mandatory objectives)
2
Copyright © 2014 EDM Council Inc.
BCBS 239 IN CONTEXT
Confidential 3
Copyright © 2015 EDM Council Inc.
Principle 1: The Governance Mandate
Implications: Establish the RDA framework, fully documented, appropriately
resourced with no organizational barriers and top-of-the-house engagement
BCBS Findings: lack of formal/documented frameworks; need clear owners
with demarcation of responsibility; need coordination of requirements among business
IT and risk; decentralized and undocumented data policies; need better SLAs and
measurement criteria for RDA processes; need higher standard for audit of RDAR
You Ain’t Got No Choice
BCBS 239 – RISK DATA AGGREGATION
Confidential 4
Copyright © 2015 EDM Council Inc.
Principles 2,4,6: The Data Infrastructure Mandate
Implications: need integrated data architecture (taxonomies, metadata, identifiers);
need controls across the full data lifecycle; need flexible classification and aggregation;
must support on-demand, ad-hoc reporting and scenario-based reporting
BCBS Findings: inconsistent taxonomies, metadata, identifiers and dictionaries;
inability to harmonize, integrate and compare among repositories; need identification
and definition of CDE; failure to take into account interdependencies between
processes
Data Harmonization is Mandatory
BCBS 239 – RISK DATA AGGREGATION
Confidential 5
Copyright © 2015 EDM Council Inc.
Principles 3,5,7,8: The Data Quality Mandate
Implications: Risk data must be timely, accurate and comprehensive; must adopt
authoritative sources and the creation of a data control environment; need to align data
to “concepts” for consistency of meaning across the organization; must be able to
generate timely risk reporting across all dimensions of quality and all risk categories
BCBS Findings: Too much reliance on manual processes; insufficient data
reconciliation (root cause analysis and executable business rules); need better control
across lifecycle of data (data inventory, transformation mapping, cross-referencing,
authoritative sources)
Adaptability Based on Scenarios
BCBS 239 – RISK DATA AGGREGATION
Control	
  Data	
  Environment	
  
	
  
Governed	
  by	
  policy,	
  sanc2oned	
  by	
  
execu2ve	
  management,	
  based	
  on	
  
standards,	
  harmonized	
  across	
  the	
  
lifecycle,	
  with	
  clear	
  accountability	
  and	
  
monitored	
  by	
  audit	
  
	
  
Legacy	
  Environment	
  
	
  
Exis2ng	
  technical	
  and	
  
opera2onal	
  environments	
  
• Disparate	
  data	
  sets	
  
• Proprietary	
  interfaces	
  and	
  point-­‐to-­‐point	
  links	
  
• Mul2ple	
  repositories	
  managed	
  independently	
  
• Inconsistent	
  formats	
  and	
  data	
  defini2ons	
  
Alignment	
  to	
  Meaning	
  
	
  
Harmonized	
  and	
  precise	
  data	
  
based	
  on	
  contractual	
  precision	
  
• AFribute	
  level	
  business	
  glossary/business	
  conceptual	
  ontology	
  
• Unique	
  iden2fica2on	
  and	
  flexible	
  classifica2on	
  scheme	
  
• Harmoniza2on	
  and	
  transforma2on	
  processes	
  (cross-­‐referencing	
  and	
  
mapping	
  across	
  systems)	
  	
  
• Metadata	
  repository	
  (administra2ve,	
  structural,	
  descrip2ve)	
  	
  
②	
  
Manage	
  Data	
  Quality	
  
	
  
Fit-­‐for-­‐purpose	
  data	
  without	
  
reconcilia2on	
  and	
  transforma2on	
  
• Data	
  quality	
  criteria	
  (all	
  relevant	
  dimensions)	
  	
  
• Establish	
  data	
  quality	
  control	
  points	
  
• Quality	
  assessment	
  and	
  remedia2on	
  (current	
  state	
  analysis)	
  
• Define	
  business	
  rules,	
  thresholds	
  and	
  tolerances	
  
• Root	
  cause	
  analysis	
  (trace	
  to	
  source)	
  
• Management	
  of	
  data	
  manufacturing	
  chain	
  of	
  supply	
  	
  	
  
③	
  
Technical	
  Implementa=on	
  
	
  
Integrate	
  data	
  into	
  opera2onal	
  
and	
  produc2on	
  environments	
  
• PlaPorm	
  and	
  authorized	
  tool	
  stack	
  
• Messaging	
  and	
  distribu2on	
  
infrastructure	
  
• Seman2c	
  to	
  logical	
  data	
  model	
  
• Logical	
  to	
  physical	
  instan2a2on	
  
• Loca2on	
  iden2fiers	
  and	
  namespace	
  
management	
  	
  	
  
④	
  
Copyright	
  ©	
  2015	
  EDM	
  Council	
  Inc.	
  
Scope of Work Required to Achieve a Control Environment
6	
  
Simple
Complicated Simplifica=on	
  
	
  
Reconcilia2on	
  of	
  complex	
  
environments	
  
• Designa2on	
  of	
  “authorized	
  data	
  domains”	
  	
  
• Defini2on	
  of	
  cri2cal	
  data	
  elements	
  (CDEs)	
  
• Documenta2on	
  of	
  end-­‐to-­‐end	
  data	
  flows	
  
(compounding	
  process,	
  derived	
  calcula2ons,	
  
risk	
  and	
  business	
  formulas)	
  	
  
①	
  
Confidential
Unique Identification
7
Copyright © 2015 EDM Council Inc.
Precise Description
Structured Messaging
Data Lineage
• Document	
  end-­‐to-­‐end	
  data	
  flows	
  (compounding	
  process,	
  derived	
  
calcula2ons,	
  risk	
  and	
  business	
  formulas)	
  	
  
• Designate	
  “authorized	
  data	
  domains”	
  	
  
• Define	
  cri2cal	
  data	
  elements	
  (CDEs)	
  	
  
• Implement	
  metadata	
  linkages	
  (administra2ve,	
  structural,	
  
descrip2ve)	
  	
  
Data Quality
• Completeness,	
  coverage,	
  conformity,	
  consistency,	
  accuracy,	
  
duplica2on,	
  2meliness	
  
• Establish	
  data	
  quality	
  control	
  points	
  
• Perform	
  quality	
  assessment	
  and	
  remedia2on	
  (current	
  state	
  analysis)	
  
• Define	
  business	
  rules,	
  thresholds	
  and	
  tolerances	
  
• Conduct	
  root	
  cause	
  analysis	
  (trace	
  to	
  source)	
  
• Manage	
  data	
  manufacturing	
  chain	
  of	
  supply	
  	
  	
  
Integration
• Align	
  to	
  meaning	
  (business	
  conceptual	
  ontology)	
  
• Implement	
  unique	
  iden2fica2on	
  and	
  flexible	
  classifica2on	
  
• Manage	
  harmoniza2on	
  and	
  transforma2on	
  processes	
  (cross-­‐
referencing	
  and	
  mapping	
  across	
  systems)	
  
• Implement	
  messaging	
  and	
  distribu2on	
  infrastructure	
  
• Seman2c	
  	
  defini2on	
  à	
  logical	
  data	
  model	
  à	
  physical	
  instan2a2on	
  
THE CRITICAL COMPONENTS OF “CONTROL ENVIRONMENT”
Confidential Copyright © 2014 EDM Council Inc. Page 8
• G-SIBs and D-SIBs are engaged in remediation
(G-SIBs spend ~ $230m; D-SIBs are far behind)
• Typically led by Group Risk (leveraging existing initiatives)
• Progress on “foundational governance” (not implemented
across enterprise)
• Most RADR initiatives are focused on adherence
(have not calculated business value/benefits)
• Data architecture (lineage, taxonomies, harmonization)
and reliance on manual processes remain as the big
challenges because of magnitude
• Top remediation priorities (in order): data dictionary/taxonomy,
data quality monitoring, data consistency between risk
and finance, alignment of repositories, process automation
• Remediation challenges are significant (IT architecture and
data flows are complex and require extensive work)
• Over 70% of banks have defined the “high level” requirements
for adherence but have not translated them into specific data
and architecture initiatives
BCBS 239 – CURRENT STATUS
Confidential Copyright © 2015 EDM Council Inc. Page 9
• Dodd-Frank Act Title IV, VII, X, XIV = US framework for regulation of swaps markets, hedge funds, CFPB, mortgage, Volker
• EMIR – European Market Infrastructure Regulation (EU version of Dodd-Frank Title VII on derivatives transparency).
• Regulation AB2 = regulations on asset backed securities (unravel links between loan, tranches, pool, etc.).
• FATCA = individual reporting of foreign accounts and FSI reporting of foreign financial accounts about US clients
• UCITS = Undertakings for Collective Investment in Transferable Securities (EU Directive on simplification of prospectus and
their expression using clear, accessible and standardized data).
• AIFMD – Alternative Investment Fund Managers Directive (EU proposed law to provide more oversight and transparency to
hedge funds and private equity).
• Dodd-Frank Act Title I = the financial stability component (creates Financial Stability Oversight Council and OFR)
• EU System of Financial Supervision = establishment of the European Systemic Risk Board (and ESFS)
• Basel Principles for Effective Risk Data Aggregation and Reporting = implementation of a “data control environment” and
healthy “risk appetite framework” within systemically important financial institutions
• Basel III – global regulatory standard on bank capital adequacy, stress testing and market liquidity risk.
• CCAR = Comprehensive Capital Analysis and Review (stress test methodology in the US; CCAR reporting is putting lots of
pressure on data alignment and comparability. This includes the FR Y-9C (Bank Holding Company Capital Report) and FR
Y-14Q (detailed ‘show your calculation methodology work for BHC). This is the US version of Basel III.
• Solvency II – EU Directive that harmonizes insurance regulation (requirements for capital reserve and reduction of risk of
insolvency) – to be implemented January 2014.
• MiFID II – Revised Markets in Financial Instruments Directive (mostly about trading, but does require common instrument
identification for consolidated pricing).
• ACORD – Insurance standards development body (UK) likely to be mandated as the format for reporting.
• Regulation SCI – SEC proposed Regulation Systems Compliance and Integrity (to ensure that core infrastructure is functional)
• COREP = Common Reporting requirements (developed by Committee of European Banking Supervisors (CEBS) with the goal
of developing a supervisory reporting framework based on common data standards and formats.
• FSB Templates = Common Data Template for G-SIB’s seeking to harmonize the data compounding
methodology for reporting.
Transparency
Capital
Risk/Stress
Harmonization
CORE REGULATORY INITIATIVES
Confidential Copyright © 2015 EDM Council Inc.
Page 10
Intersection of data management best practice and
the reality of financial services operations
Based on Collective Experience
• Synthesis of research and analysis among practitioners since formation of EDM Council (case
studies, regulatory pressure, collaborative research)
• Socratic method to ensure that DCAM is practical and in line with the core principles of data
management (philosophy meets practical reality)
• Aligns with organizational mandate (practical, works in real world, understandable by non-
specialists, based on collaboration, structured for continual improvement)
• Standard criteria for evaluation of capability … linked to benchmarking … providing evidence of
adoption of control environment
DATA MANAGEMENT CAPABILITY ASSESSMENT MODEL
Confidential Copyright © 2015 EDM Council Inc.
Page 11
DATA MANAGEMENT CAPABILITY ASSESSMENT MODEL
DCAM
Construction
Capability
Sub-Capability
Objectives
Artifacts
Required
Purpose
Statement
(what is and why
important)
Management
Context
(definition and
introduction)
Elaboration
Specific Goals
Core
Questions
Informative
Capability
Type
Data-related (identification,
common language, classification,
data quality, lineage, compounding
process)
Organization-related (governance,
funding, data management program)
Ecosystem-related (IT, operations,
security, privacy, finance)
Organizational
Confidential Copyright © 2015 EDM Council Inc.
Page 12
• Created based on practical experience
• Capabilities orientation: Not done; In process (low,
medium, high); Capability achieved; Capability enhanced
• Each Category is defined by a set of
Capabilities and Sub-Capabilities
• Each Sub-capability is evidenced by a series
of capability objectives
Data
Management
Strategy
Defines the long term goal of the data management
program. The blueprint to gain internal alignment
among stakeholders and to define how the organization
will approach the management of data content
Data
Management
Business
Case
The justification for the data management program. The
mechanism for ensuring sufficient and sustainable
capital. The approach for measuring the costs and
benefits of EDM
Data
Management
Program
The mechanism for EDM implementation. Stakeholder
engagement. Communications program and education
on the concepts of data CONTENT management.
Engagement model and operational routines
Data
Governance
The rules of engagement for implementation of the data
management program. The focus is on implementation
of policies, standards and operational procedures
necessary to ensure that stakeholders “behave”
Data
Architecture
The “design of information content” including the
identification of data domains, establishment of
taxonomies, alignment with contractual obligations,
documentation of metadata and designation of CDEs
Technology
Architecture
The “design of physical architecture” including the
platforms and tools in support of data management
implementation. This is domain of IT and defines how
data is acquired, stored, integrated and distributed
Data
Quality
Deliver to business users data that is fit-for-purpose.
The goal is data that users trust and have confidence in
to be exactly what they expect it to be without the need
for reconciliation and data transformation
Data
Control
Environment
Coordination of the components into a cohesive
operational model; ensure that controls are in place for
consistency across the lifecycle; align with
organizational privacy and security policies
Component	
  (8)	
  
Capability	
  (36)	
  
Sub-­‐Capability	
  (112)	
  
Objec=ves	
  (306)	
  
DATA MANAGEMENT CAPABILITY ASSESSMENT MODEL
Confidential Copyright © 2015 EDM Council Inc.
Page 13
DATA MANAGEMENT STRATEGY
Blueprint defining the goals of the data management program
and how the organization will approach implementation
Establish the framework
for the data management
program including how it
will be defined,
organized, funded and
governed
Clearly define the goals,
objectives and scope of
the program to ensure
alignment and
commitment from the
critical stakeholders
Articulate how the
program will be
practically implemented
including how it aligns
with business value and
organizational objectives
Confidential Copyright © 2015 EDM Council Inc.
Page 14
Data Management Strategy Capabilities
DATA MANAGEMENT STRATEGY
❶ Data management strategy is
specified and shared
❷
High level business
requirements are captured
and integrated into the DMS
❸
DMS defines the importance of
defining and appropriately using
“authorized data domains”
❹
DMS is aligned and mapped to
architectural, IT and
operational capabilities
❺
DMS requires the
creation of a formal
governance program
❻
DMS defines how the
data management
program will be
measured and
evaluated
{
DMS calls for the
creation of a
communications and
training program
Confidential Copyright © 2015 EDM Council Inc. Page 15
DATA MANAGEMENT BUSINESS CASE & FUNDING MODEL
The justification for the data management program including
how it is funded and evaluated
Mechanism to ensure
allocation of sufficient
capital and methodology
for cost allocation
Approach used to
measure costs and
contributions from the
data management
program
Rationale for the
investment in data
management including
the costs, benefits, risks
and expected outcomes
Confidential Copyright © 2015 EDM Council Inc. Page 16
Data Management Business Case & Funding Model Capabilities
DATA MANAGEMENT BUSINESS CASE & FUNDING MODEL
The data management business case is aligned to
strategic drivers and tangible business outcomes
❶
The data management funding model has been
established, approved and adopted by the
organization
❷
The funding model can be measured and
evaluated against tangible business objectives
❸
Confidential Copyright © 2015 EDM Council Inc. Page 17
DATA MANAGEMENT PROGRAM
Establish the data management function and ensure that it operates
effectively within the culture of your organization
Clear understanding of
the meaning of data
“content” management
and why it is essential to
the operations of the
organization
Establish an operational
framework to ensure
sustainability and
authority of the data
management program
Establish and confirm
stakeholder engagement
along with the process to
ensure that the data
management program is
implemented
Confidential Copyright © 2015 EDM Council Inc. Page 18
DATA MANAGEMENT PROGRAM
Data Management Program Capabilities
Implement the Data Management
Program Organizational Structure
❷
Roadmaps are developed,
socialized and approved
❸
Stakeholder engagement is
established and confirmed
❹
Communication
Program is designed
and operational
❺
Data Management routines are
established and operational
❻
Establish and Empower the
Data Management Program
❶
Confidential Copyright © 2015 EDM Council Inc. Page 19
DATA GOVERNANCE
Rules of engagement necessary for implementation of the
data management program
Establish the structure
and operating model
needed to establish lines
of authority and integrate
the DMP into the
corporate hierarchy
Define, implement and
enforce data
management policies,
procedures, guidelines
and standards
Measure and monitor the
effectiveness of the data
management program
and ensure sufficient
resources have been
allocated
Confidential Copyright © 2015 EDM Council Inc. Page 20
Data Management Strategy Capabilities
DATA GOVERNANCE
❶ Data governance
structure is created
❷
Thing
Independ
ent Thing
Person
Relative
Thing
Employe
e
Custome
r Pilot
Mediatin
g Thing
(context)
Employm
ent Sales Aviation
Content governance is defined
❸ Policy and standards are
written and approved
❹ Program governance is
operational
❺
Program
governance
controls are in
place
❻
Technology
governance is
aligned
{
Cross-
organizational
enterprise data
governance is
aligned
Confidential Copyright © 2015 EDM Council Inc. Page 21
DATA ARCHITECTURE
Design, management, implementation and maintenance of the
precise meaning of the information
Definition of the precise
contractual meaning of all
data attributes including
how they relate to one
another and their
expression as metadata
Governance procedures
to ensure the
maintenance, control and
appropriate use of data
and its harmonization to
business meaning
Identification of (and
agreement on) the logical
domains of data
as well as location of the
underlying physical
repositories
Confidential Copyright © 2015 EDM Council Inc. Page 22
DATA ARCHITECTURE
❶
Identify the data (logically
and physically)
❷ Define the data (semantically and
structurally)
❸
Govern the data
(establish sustainable
data architecture
governance)
Data Architecture Capabilities
Confidential Copyright © 2015 EDM Council Inc. Page 23
TECHNOLOGY ARCHITECTURE
Physical architecture and how data is acquired, stored,
distributed and integrated across the organization
Strategy, architecture,
roadmaps and
governance on the
physical IT infrastructure
needed to support data
management objectives
Definition of the allowable
tool stacks (i.e. BI, ETL,
storage) needed to
support implementation
of the data management
strategy
Strategies and
approaches to address
operational risk, business
continuity and disaster
recovery
Confidential Copyright © 2015 EDM Council Inc. Page 24
TECHNOLOGY ARCHITECTURE
❶
Technology
architecture
is defined and
governed
❸
Data storage
management
strategy is
defined and
governed
❹ Operational risk
planning is in place
Technology Architecture Capabilities
Data technology
tool stack is
defined and
governed
❷
Confidential Copyright © 2015 EDM Council Inc. Page 25
DATA QUALITY PROGRAM
Approach to ensure that data consumers trust and have
confidence in the data as fit for their intended purpose
Implement data quality
governance mechanisms
and processes for
management of the data
manufacturing chain of
supply
Establish the goals,
approaches, dimensions
and plans of action to
ensure data content
supports the objectives of
the organization
Create a profile of the
current state of data
quality, identify areas that
need remediation and
cleanse against approved
business rules
Confidential Copyright © 2015 EDM Council Inc. Page 26
DATA QUALITY PROGRAM
❶
Data quality
program is
established
❷
Quality of existing stores of
data are identified and assessed
Quality of new data is
monitored, analyzed
and reported
❸
Data Quality Capabilities
Confidential Copyright © 2015 EDM Council Inc. Page 27
DATA CONTROL ENVIRONMENT
Coordination of the components of the data lifecycle across
the data ecosystem of the organization
Objectives and
capabilities of the data
management program
are embraced and
adopted throughout the
organization – creating a
control environment
Identification and
documentation of the
end-to-end data flows
and reverse engineering
of data compounding
processes (formulas,
derived calculations, etc.)
Integration of data
management into the
organizational
“ecosystem” and
alignment with other
enterprise control
functions
Confidential Copyright © 2015 EDM Council Inc. Page 28
DATA CONTROL ENVIRONMENT
❶ A data control environment is
established and operational
❸
Control environment ensures that the
discipline of data management is
operating collaboratively with cross-
organizational control functions
Data Control Environment Capabilities
❷
A data control
environment
supports the data
management
lifecycle
Confidential Copyright © 2015 EDM Council Inc.
Page 29
Process Formality Engagement
Not Initiated
Capabilities are not Being Performed
Tactical Ad Hoc Heroes
In Process
(Conceptual)
Capabilities are in their Initial Planning Stages
Issues are under debate White board planning Data practitioners
In Process
(Developmental)
Capabilities are Being Developed
Policies, procedures, standards, roles
and accountabilities are being
established
Meetings are underway
(notes and planning documents)
Stakeholders are identified
(negotiated resources/annual
budgets)
In Process
(Defined)
Capabilities are Defined and Formalized
Policies and standards exist
(roles, responsibilities and
accountabilities are being coordinated)
Routines exist
(structured documentation)
Verified by stakeholders
(business and functional
responsibility/sustainable funding)
Achieved
Capabilities are Achieved and Implemented
Policies and standards are
implemented
(proactive issue management)
Capabilities are embedded into
operations
(standardized methodologies)
Executive management authority
(strategic investment funding)
Enhanced Capabilities are fully integrated into the operating culture of the organization
DATA MANAGEMENT CAPABILITY ASSESSMENT MODEL
DCAM Scoring Philosophy
Confidential
1. Confidence Rule: We have an endorsed data
management strategy that is meaningful to business
users
2. Owner Rule: We have a senior executive (with
authority) in charge of the data management program
3. Alignment Rule: Stakeholders understand (and buy
into) the need for the data management program
4. Communication Rule: We do a good job
communicating the value proposition and operational
implications of the data management program
5. Business Case Rule: The business case and funding
model for the data management program is
established and operational
6. Metrics Rule: We do a good job of measuring the
costs and benefits of the data management program
7. Policy Rule: The data management program has the
authority to enforce adherence to policy
8. Resources Rule: The data management program has
enough resources to be sustainable
9. Accountability Rule: The data management
governance and accountability structures are
operational
10.Responsibility Rule: The roles and responsibilities of
data “owners” and “stewards” are assigned
11. Enforcement Rule: Data policies and standards are
implemented and enforced
12. Ontology Rule: The business meaning of data is
defined, governed and harmonized across repositories
13. CDE Rule: Critical data elements are identified, verified
and managed
14. Data Domains Rule: Logical categories of data have
been defined and catalogued
15. Capability Rule: The data management program is
aligned with technical and operational capabilities
16. Profiling Rule: Data in existing repositories has been
profiled, analyzed and graded
17. DQ Control Rule: Data quality control procedures,
business rules and measurement criteria are operational
18. Root Cause Rule: The root cause of data quality
problems are identified and corrected
19. Lineage Rule: End-to-end data lineage has been
identified across the full data lifecycle
20. Ecosystem Rule: Data management collaborates with
existing enterprise control functions
30
Copyright © 2015 EDM Council Inc.
EDM Council’s 20 Rules of Data Management
Confidential Copyright © 2015 EDM Council Inc.
Page 31
Operational
Efficiency
Trust &
Confidence
Flexible Data
Infrastructure
Commercial
Insight
Sphere
of Value
• Reconciliation & manual processes
• Trade repairs & fails
• Settlement instruction mismatches
• Corporate actions processing
• Redundant systems
• Capital reserve/unproductive capital
• Transformation & integration
challenges
• Risk analysis & reporting
• Compliance requirements
• Derived data, calculations
and analytical models
• Business process automation
• Management & financial
reporting
• Upselling opportunities
• Enhanced customer service
• New product engineering
• Product & client ROI
• Sentiment and contextual
analysis
• Classification and
aggregation capabilities
• Flexible queries
• Data harmonization
• Adaptability
• Extensibility
• Structural data quality
BUSINESS VALUE TO BE REALIZED

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DCAM_Overview.pdf_______________________

  • 1. Confidential Copyright © 2015 EDM Council Inc. Page 1 Data Management Capabilities Assessment Model (DCAM)
  • 2. Confidential Copyright © 2015 EDM Council Inc. Page 2 • 2008 Crisis: Inability to model contagion (who finances who, who is linked to who, what are the obligations of complex financial instruments) • Senior Banking Supervisors Group: Observations on Developments in Risk Appetite Frameworks and IT Infrastructure (intractable relationship between data and risk management and definition of control environment) • BCBS 239: Principles of Risk Data Aggregation and Reporting (governance, content infrastructure and data quality as mandatory objectives) 2 Copyright © 2014 EDM Council Inc. BCBS 239 IN CONTEXT
  • 3. Confidential 3 Copyright © 2015 EDM Council Inc. Principle 1: The Governance Mandate Implications: Establish the RDA framework, fully documented, appropriately resourced with no organizational barriers and top-of-the-house engagement BCBS Findings: lack of formal/documented frameworks; need clear owners with demarcation of responsibility; need coordination of requirements among business IT and risk; decentralized and undocumented data policies; need better SLAs and measurement criteria for RDA processes; need higher standard for audit of RDAR You Ain’t Got No Choice BCBS 239 – RISK DATA AGGREGATION
  • 4. Confidential 4 Copyright © 2015 EDM Council Inc. Principles 2,4,6: The Data Infrastructure Mandate Implications: need integrated data architecture (taxonomies, metadata, identifiers); need controls across the full data lifecycle; need flexible classification and aggregation; must support on-demand, ad-hoc reporting and scenario-based reporting BCBS Findings: inconsistent taxonomies, metadata, identifiers and dictionaries; inability to harmonize, integrate and compare among repositories; need identification and definition of CDE; failure to take into account interdependencies between processes Data Harmonization is Mandatory BCBS 239 – RISK DATA AGGREGATION
  • 5. Confidential 5 Copyright © 2015 EDM Council Inc. Principles 3,5,7,8: The Data Quality Mandate Implications: Risk data must be timely, accurate and comprehensive; must adopt authoritative sources and the creation of a data control environment; need to align data to “concepts” for consistency of meaning across the organization; must be able to generate timely risk reporting across all dimensions of quality and all risk categories BCBS Findings: Too much reliance on manual processes; insufficient data reconciliation (root cause analysis and executable business rules); need better control across lifecycle of data (data inventory, transformation mapping, cross-referencing, authoritative sources) Adaptability Based on Scenarios BCBS 239 – RISK DATA AGGREGATION
  • 6. Control  Data  Environment     Governed  by  policy,  sanc2oned  by   execu2ve  management,  based  on   standards,  harmonized  across  the   lifecycle,  with  clear  accountability  and   monitored  by  audit     Legacy  Environment     Exis2ng  technical  and   opera2onal  environments   • Disparate  data  sets   • Proprietary  interfaces  and  point-­‐to-­‐point  links   • Mul2ple  repositories  managed  independently   • Inconsistent  formats  and  data  defini2ons   Alignment  to  Meaning     Harmonized  and  precise  data   based  on  contractual  precision   • AFribute  level  business  glossary/business  conceptual  ontology   • Unique  iden2fica2on  and  flexible  classifica2on  scheme   • Harmoniza2on  and  transforma2on  processes  (cross-­‐referencing  and   mapping  across  systems)     • Metadata  repository  (administra2ve,  structural,  descrip2ve)     ②   Manage  Data  Quality     Fit-­‐for-­‐purpose  data  without   reconcilia2on  and  transforma2on   • Data  quality  criteria  (all  relevant  dimensions)     • Establish  data  quality  control  points   • Quality  assessment  and  remedia2on  (current  state  analysis)   • Define  business  rules,  thresholds  and  tolerances   • Root  cause  analysis  (trace  to  source)   • Management  of  data  manufacturing  chain  of  supply       ③   Technical  Implementa=on     Integrate  data  into  opera2onal   and  produc2on  environments   • PlaPorm  and  authorized  tool  stack   • Messaging  and  distribu2on   infrastructure   • Seman2c  to  logical  data  model   • Logical  to  physical  instan2a2on   • Loca2on  iden2fiers  and  namespace   management       ④   Copyright  ©  2015  EDM  Council  Inc.   Scope of Work Required to Achieve a Control Environment 6   Simple Complicated Simplifica=on     Reconcilia2on  of  complex   environments   • Designa2on  of  “authorized  data  domains”     • Defini2on  of  cri2cal  data  elements  (CDEs)   • Documenta2on  of  end-­‐to-­‐end  data  flows   (compounding  process,  derived  calcula2ons,   risk  and  business  formulas)     ①  
  • 7. Confidential Unique Identification 7 Copyright © 2015 EDM Council Inc. Precise Description Structured Messaging Data Lineage • Document  end-­‐to-­‐end  data  flows  (compounding  process,  derived   calcula2ons,  risk  and  business  formulas)     • Designate  “authorized  data  domains”     • Define  cri2cal  data  elements  (CDEs)     • Implement  metadata  linkages  (administra2ve,  structural,   descrip2ve)     Data Quality • Completeness,  coverage,  conformity,  consistency,  accuracy,   duplica2on,  2meliness   • Establish  data  quality  control  points   • Perform  quality  assessment  and  remedia2on  (current  state  analysis)   • Define  business  rules,  thresholds  and  tolerances   • Conduct  root  cause  analysis  (trace  to  source)   • Manage  data  manufacturing  chain  of  supply       Integration • Align  to  meaning  (business  conceptual  ontology)   • Implement  unique  iden2fica2on  and  flexible  classifica2on   • Manage  harmoniza2on  and  transforma2on  processes  (cross-­‐ referencing  and  mapping  across  systems)   • Implement  messaging  and  distribu2on  infrastructure   • Seman2c    defini2on  à  logical  data  model  à  physical  instan2a2on   THE CRITICAL COMPONENTS OF “CONTROL ENVIRONMENT”
  • 8. Confidential Copyright © 2014 EDM Council Inc. Page 8 • G-SIBs and D-SIBs are engaged in remediation (G-SIBs spend ~ $230m; D-SIBs are far behind) • Typically led by Group Risk (leveraging existing initiatives) • Progress on “foundational governance” (not implemented across enterprise) • Most RADR initiatives are focused on adherence (have not calculated business value/benefits) • Data architecture (lineage, taxonomies, harmonization) and reliance on manual processes remain as the big challenges because of magnitude • Top remediation priorities (in order): data dictionary/taxonomy, data quality monitoring, data consistency between risk and finance, alignment of repositories, process automation • Remediation challenges are significant (IT architecture and data flows are complex and require extensive work) • Over 70% of banks have defined the “high level” requirements for adherence but have not translated them into specific data and architecture initiatives BCBS 239 – CURRENT STATUS
  • 9. Confidential Copyright © 2015 EDM Council Inc. Page 9 • Dodd-Frank Act Title IV, VII, X, XIV = US framework for regulation of swaps markets, hedge funds, CFPB, mortgage, Volker • EMIR – European Market Infrastructure Regulation (EU version of Dodd-Frank Title VII on derivatives transparency). • Regulation AB2 = regulations on asset backed securities (unravel links between loan, tranches, pool, etc.). • FATCA = individual reporting of foreign accounts and FSI reporting of foreign financial accounts about US clients • UCITS = Undertakings for Collective Investment in Transferable Securities (EU Directive on simplification of prospectus and their expression using clear, accessible and standardized data). • AIFMD – Alternative Investment Fund Managers Directive (EU proposed law to provide more oversight and transparency to hedge funds and private equity). • Dodd-Frank Act Title I = the financial stability component (creates Financial Stability Oversight Council and OFR) • EU System of Financial Supervision = establishment of the European Systemic Risk Board (and ESFS) • Basel Principles for Effective Risk Data Aggregation and Reporting = implementation of a “data control environment” and healthy “risk appetite framework” within systemically important financial institutions • Basel III – global regulatory standard on bank capital adequacy, stress testing and market liquidity risk. • CCAR = Comprehensive Capital Analysis and Review (stress test methodology in the US; CCAR reporting is putting lots of pressure on data alignment and comparability. This includes the FR Y-9C (Bank Holding Company Capital Report) and FR Y-14Q (detailed ‘show your calculation methodology work for BHC). This is the US version of Basel III. • Solvency II – EU Directive that harmonizes insurance regulation (requirements for capital reserve and reduction of risk of insolvency) – to be implemented January 2014. • MiFID II – Revised Markets in Financial Instruments Directive (mostly about trading, but does require common instrument identification for consolidated pricing). • ACORD – Insurance standards development body (UK) likely to be mandated as the format for reporting. • Regulation SCI – SEC proposed Regulation Systems Compliance and Integrity (to ensure that core infrastructure is functional) • COREP = Common Reporting requirements (developed by Committee of European Banking Supervisors (CEBS) with the goal of developing a supervisory reporting framework based on common data standards and formats. • FSB Templates = Common Data Template for G-SIB’s seeking to harmonize the data compounding methodology for reporting. Transparency Capital Risk/Stress Harmonization CORE REGULATORY INITIATIVES
  • 10. Confidential Copyright © 2015 EDM Council Inc. Page 10 Intersection of data management best practice and the reality of financial services operations Based on Collective Experience • Synthesis of research and analysis among practitioners since formation of EDM Council (case studies, regulatory pressure, collaborative research) • Socratic method to ensure that DCAM is practical and in line with the core principles of data management (philosophy meets practical reality) • Aligns with organizational mandate (practical, works in real world, understandable by non- specialists, based on collaboration, structured for continual improvement) • Standard criteria for evaluation of capability … linked to benchmarking … providing evidence of adoption of control environment DATA MANAGEMENT CAPABILITY ASSESSMENT MODEL
  • 11. Confidential Copyright © 2015 EDM Council Inc. Page 11 DATA MANAGEMENT CAPABILITY ASSESSMENT MODEL DCAM Construction Capability Sub-Capability Objectives Artifacts Required Purpose Statement (what is and why important) Management Context (definition and introduction) Elaboration Specific Goals Core Questions Informative Capability Type Data-related (identification, common language, classification, data quality, lineage, compounding process) Organization-related (governance, funding, data management program) Ecosystem-related (IT, operations, security, privacy, finance) Organizational
  • 12. Confidential Copyright © 2015 EDM Council Inc. Page 12 • Created based on practical experience • Capabilities orientation: Not done; In process (low, medium, high); Capability achieved; Capability enhanced • Each Category is defined by a set of Capabilities and Sub-Capabilities • Each Sub-capability is evidenced by a series of capability objectives Data Management Strategy Defines the long term goal of the data management program. The blueprint to gain internal alignment among stakeholders and to define how the organization will approach the management of data content Data Management Business Case The justification for the data management program. The mechanism for ensuring sufficient and sustainable capital. The approach for measuring the costs and benefits of EDM Data Management Program The mechanism for EDM implementation. Stakeholder engagement. Communications program and education on the concepts of data CONTENT management. Engagement model and operational routines Data Governance The rules of engagement for implementation of the data management program. The focus is on implementation of policies, standards and operational procedures necessary to ensure that stakeholders “behave” Data Architecture The “design of information content” including the identification of data domains, establishment of taxonomies, alignment with contractual obligations, documentation of metadata and designation of CDEs Technology Architecture The “design of physical architecture” including the platforms and tools in support of data management implementation. This is domain of IT and defines how data is acquired, stored, integrated and distributed Data Quality Deliver to business users data that is fit-for-purpose. The goal is data that users trust and have confidence in to be exactly what they expect it to be without the need for reconciliation and data transformation Data Control Environment Coordination of the components into a cohesive operational model; ensure that controls are in place for consistency across the lifecycle; align with organizational privacy and security policies Component  (8)   Capability  (36)   Sub-­‐Capability  (112)   Objec=ves  (306)   DATA MANAGEMENT CAPABILITY ASSESSMENT MODEL
  • 13. Confidential Copyright © 2015 EDM Council Inc. Page 13 DATA MANAGEMENT STRATEGY Blueprint defining the goals of the data management program and how the organization will approach implementation Establish the framework for the data management program including how it will be defined, organized, funded and governed Clearly define the goals, objectives and scope of the program to ensure alignment and commitment from the critical stakeholders Articulate how the program will be practically implemented including how it aligns with business value and organizational objectives
  • 14. Confidential Copyright © 2015 EDM Council Inc. Page 14 Data Management Strategy Capabilities DATA MANAGEMENT STRATEGY ❶ Data management strategy is specified and shared ❷ High level business requirements are captured and integrated into the DMS ❸ DMS defines the importance of defining and appropriately using “authorized data domains” ❹ DMS is aligned and mapped to architectural, IT and operational capabilities ❺ DMS requires the creation of a formal governance program ❻ DMS defines how the data management program will be measured and evaluated { DMS calls for the creation of a communications and training program
  • 15. Confidential Copyright © 2015 EDM Council Inc. Page 15 DATA MANAGEMENT BUSINESS CASE & FUNDING MODEL The justification for the data management program including how it is funded and evaluated Mechanism to ensure allocation of sufficient capital and methodology for cost allocation Approach used to measure costs and contributions from the data management program Rationale for the investment in data management including the costs, benefits, risks and expected outcomes
  • 16. Confidential Copyright © 2015 EDM Council Inc. Page 16 Data Management Business Case & Funding Model Capabilities DATA MANAGEMENT BUSINESS CASE & FUNDING MODEL The data management business case is aligned to strategic drivers and tangible business outcomes ❶ The data management funding model has been established, approved and adopted by the organization ❷ The funding model can be measured and evaluated against tangible business objectives ❸
  • 17. Confidential Copyright © 2015 EDM Council Inc. Page 17 DATA MANAGEMENT PROGRAM Establish the data management function and ensure that it operates effectively within the culture of your organization Clear understanding of the meaning of data “content” management and why it is essential to the operations of the organization Establish an operational framework to ensure sustainability and authority of the data management program Establish and confirm stakeholder engagement along with the process to ensure that the data management program is implemented
  • 18. Confidential Copyright © 2015 EDM Council Inc. Page 18 DATA MANAGEMENT PROGRAM Data Management Program Capabilities Implement the Data Management Program Organizational Structure ❷ Roadmaps are developed, socialized and approved ❸ Stakeholder engagement is established and confirmed ❹ Communication Program is designed and operational ❺ Data Management routines are established and operational ❻ Establish and Empower the Data Management Program ❶
  • 19. Confidential Copyright © 2015 EDM Council Inc. Page 19 DATA GOVERNANCE Rules of engagement necessary for implementation of the data management program Establish the structure and operating model needed to establish lines of authority and integrate the DMP into the corporate hierarchy Define, implement and enforce data management policies, procedures, guidelines and standards Measure and monitor the effectiveness of the data management program and ensure sufficient resources have been allocated
  • 20. Confidential Copyright © 2015 EDM Council Inc. Page 20 Data Management Strategy Capabilities DATA GOVERNANCE ❶ Data governance structure is created ❷ Thing Independ ent Thing Person Relative Thing Employe e Custome r Pilot Mediatin g Thing (context) Employm ent Sales Aviation Content governance is defined ❸ Policy and standards are written and approved ❹ Program governance is operational ❺ Program governance controls are in place ❻ Technology governance is aligned { Cross- organizational enterprise data governance is aligned
  • 21. Confidential Copyright © 2015 EDM Council Inc. Page 21 DATA ARCHITECTURE Design, management, implementation and maintenance of the precise meaning of the information Definition of the precise contractual meaning of all data attributes including how they relate to one another and their expression as metadata Governance procedures to ensure the maintenance, control and appropriate use of data and its harmonization to business meaning Identification of (and agreement on) the logical domains of data as well as location of the underlying physical repositories
  • 22. Confidential Copyright © 2015 EDM Council Inc. Page 22 DATA ARCHITECTURE ❶ Identify the data (logically and physically) ❷ Define the data (semantically and structurally) ❸ Govern the data (establish sustainable data architecture governance) Data Architecture Capabilities
  • 23. Confidential Copyright © 2015 EDM Council Inc. Page 23 TECHNOLOGY ARCHITECTURE Physical architecture and how data is acquired, stored, distributed and integrated across the organization Strategy, architecture, roadmaps and governance on the physical IT infrastructure needed to support data management objectives Definition of the allowable tool stacks (i.e. BI, ETL, storage) needed to support implementation of the data management strategy Strategies and approaches to address operational risk, business continuity and disaster recovery
  • 24. Confidential Copyright © 2015 EDM Council Inc. Page 24 TECHNOLOGY ARCHITECTURE ❶ Technology architecture is defined and governed ❸ Data storage management strategy is defined and governed ❹ Operational risk planning is in place Technology Architecture Capabilities Data technology tool stack is defined and governed ❷
  • 25. Confidential Copyright © 2015 EDM Council Inc. Page 25 DATA QUALITY PROGRAM Approach to ensure that data consumers trust and have confidence in the data as fit for their intended purpose Implement data quality governance mechanisms and processes for management of the data manufacturing chain of supply Establish the goals, approaches, dimensions and plans of action to ensure data content supports the objectives of the organization Create a profile of the current state of data quality, identify areas that need remediation and cleanse against approved business rules
  • 26. Confidential Copyright © 2015 EDM Council Inc. Page 26 DATA QUALITY PROGRAM ❶ Data quality program is established ❷ Quality of existing stores of data are identified and assessed Quality of new data is monitored, analyzed and reported ❸ Data Quality Capabilities
  • 27. Confidential Copyright © 2015 EDM Council Inc. Page 27 DATA CONTROL ENVIRONMENT Coordination of the components of the data lifecycle across the data ecosystem of the organization Objectives and capabilities of the data management program are embraced and adopted throughout the organization – creating a control environment Identification and documentation of the end-to-end data flows and reverse engineering of data compounding processes (formulas, derived calculations, etc.) Integration of data management into the organizational “ecosystem” and alignment with other enterprise control functions
  • 28. Confidential Copyright © 2015 EDM Council Inc. Page 28 DATA CONTROL ENVIRONMENT ❶ A data control environment is established and operational ❸ Control environment ensures that the discipline of data management is operating collaboratively with cross- organizational control functions Data Control Environment Capabilities ❷ A data control environment supports the data management lifecycle
  • 29. Confidential Copyright © 2015 EDM Council Inc. Page 29 Process Formality Engagement Not Initiated Capabilities are not Being Performed Tactical Ad Hoc Heroes In Process (Conceptual) Capabilities are in their Initial Planning Stages Issues are under debate White board planning Data practitioners In Process (Developmental) Capabilities are Being Developed Policies, procedures, standards, roles and accountabilities are being established Meetings are underway (notes and planning documents) Stakeholders are identified (negotiated resources/annual budgets) In Process (Defined) Capabilities are Defined and Formalized Policies and standards exist (roles, responsibilities and accountabilities are being coordinated) Routines exist (structured documentation) Verified by stakeholders (business and functional responsibility/sustainable funding) Achieved Capabilities are Achieved and Implemented Policies and standards are implemented (proactive issue management) Capabilities are embedded into operations (standardized methodologies) Executive management authority (strategic investment funding) Enhanced Capabilities are fully integrated into the operating culture of the organization DATA MANAGEMENT CAPABILITY ASSESSMENT MODEL DCAM Scoring Philosophy
  • 30. Confidential 1. Confidence Rule: We have an endorsed data management strategy that is meaningful to business users 2. Owner Rule: We have a senior executive (with authority) in charge of the data management program 3. Alignment Rule: Stakeholders understand (and buy into) the need for the data management program 4. Communication Rule: We do a good job communicating the value proposition and operational implications of the data management program 5. Business Case Rule: The business case and funding model for the data management program is established and operational 6. Metrics Rule: We do a good job of measuring the costs and benefits of the data management program 7. Policy Rule: The data management program has the authority to enforce adherence to policy 8. Resources Rule: The data management program has enough resources to be sustainable 9. Accountability Rule: The data management governance and accountability structures are operational 10.Responsibility Rule: The roles and responsibilities of data “owners” and “stewards” are assigned 11. Enforcement Rule: Data policies and standards are implemented and enforced 12. Ontology Rule: The business meaning of data is defined, governed and harmonized across repositories 13. CDE Rule: Critical data elements are identified, verified and managed 14. Data Domains Rule: Logical categories of data have been defined and catalogued 15. Capability Rule: The data management program is aligned with technical and operational capabilities 16. Profiling Rule: Data in existing repositories has been profiled, analyzed and graded 17. DQ Control Rule: Data quality control procedures, business rules and measurement criteria are operational 18. Root Cause Rule: The root cause of data quality problems are identified and corrected 19. Lineage Rule: End-to-end data lineage has been identified across the full data lifecycle 20. Ecosystem Rule: Data management collaborates with existing enterprise control functions 30 Copyright © 2015 EDM Council Inc. EDM Council’s 20 Rules of Data Management
  • 31. Confidential Copyright © 2015 EDM Council Inc. Page 31 Operational Efficiency Trust & Confidence Flexible Data Infrastructure Commercial Insight Sphere of Value • Reconciliation & manual processes • Trade repairs & fails • Settlement instruction mismatches • Corporate actions processing • Redundant systems • Capital reserve/unproductive capital • Transformation & integration challenges • Risk analysis & reporting • Compliance requirements • Derived data, calculations and analytical models • Business process automation • Management & financial reporting • Upselling opportunities • Enhanced customer service • New product engineering • Product & client ROI • Sentiment and contextual analysis • Classification and aggregation capabilities • Flexible queries • Data harmonization • Adaptability • Extensibility • Structural data quality BUSINESS VALUE TO BE REALIZED