Weitere ähnliche Inhalte Kürzlich hochgeladen (20) User Defined Tools - Regulatory Reporting2. TABLE OF CONTENT
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USER DEFINED
TOOLS SUMMARY
HIGH PERFORMANCE
FINANCIAL REPORTING
FRAMEWORK
FINANCIAL REPORTING
PROCESS CAPABILITY MODEL
ACCENTURE REGULATORY
REPORTING OFFERINGS
USER DEFINED TOOL
ASSESSMENT APPROACH
Copyright © 2017 Accenture. All rights reserved.
What is a User Defined Tool?
Impact of Manual Data Manipulation
Approach to Evaluate UDTs
Identification and Classification of UDTs
Components of Decomposition Analysis
Prioritization Methodology – Illustrative
Tactical and Strategic Elimination Plan
Maintaining Strategic UDTs
Accelerators
3. USER DEFINED TOOLS
SUMMARY
With the new and the ever complex external
reporting landscape, Financial Institutions are
faced with a variety of challenges involving
manual intervention a.k.a. user defined tools:
• Risks associated with manual adjustments
• Operational risks
• Data accuracy
• Inaccurate report outputs
• Difficult to track and audit
Consequently, they require strategic
solutions that effectively address these
associated costs by:
• Managing ongoing risks by facilitating controls around
retained user tools
• Reducing the usage of manual activities
• Increasing the consistency and accuracy of
information through automation
Copyright © 2017 Accenture. All rights reserved. 3
Accenture has developed a tactical and strategic migration approach to assess
the complexity and business impacts affecting User Defined Tools (‘UDT’).
Accenture offers an Internal and External Regulatory Reporting Framework with a wide variety of offerings to aid our clients
in solving new and complex challenges with solutions that focus on data quality, data sourcing, and centralizing capabilities
creating efficiencies within the process.
4. Note: Please see Legend slide for definition of acronyms
HIGH PERFORMANCE FINANCIAL
REPORTING FRAMEWORK
Consolidating frameworks, processes, and technology create efficiencies across reporting functions.
External / Internal Reporting
• Same data can be used to populate reports across
the regulatory landscape and for internal purposes
reducing redundant activities
MIS / Shareholders
• With more accurate reporting results, financial results
can be produced faster
Functions
• Cross function transparency can be created allowing
for the dynamic integration of new systems
BrokerDealer
AssetManagement
Insurance
CapitalMarkets
Bank
Reporting Regulatory (External)
OCC
FDIC
NCUA
FRB
SEC
CFTC
CFPB
FHFA
FINRA
NAIC
ESFS
Basel
Functions
Risk
Treasury
Finance
Human Resources
Control
Line of Business
External Data (Market)
Legal
Workflow and Requirements
• Straight through processing of information across
all systems to help meet reporting needs
Organization
• Overarching controls and governance to help manage
risk, with well communicated roles and responsibilities
Technology
• Seamless user experience to investigate, manage
risk, and create new information and data
BENEFITS OF CONSOLIDATION
Internal Management Information System (MIS)
and Shareholders
Informational
Sr. Management
Operations
Board Actuals Forecasting
Support Organization Technology
Workflow ModelingPolicy
Training
RCSA
Procedures
Resource Location
Audit
Business Rules Performance Metrics
Calculators Aggregation
Web Services Reporting Engine
Technical Rules Batch Management
Process Workflows and Requirements
Sourcing and
Validation
Reconciliation Adjustments Transformation Distribution
Data
Management
Investigation and Analysis
Security / Audit / Controls
Copyright © 2017 Accenture. All rights reserved. 4
5. FINANCIAL REPORTING PROCESS
CAPABILITY MODEL
Level 1
Level 2
Level 3
Level 3 – Sub Category
User Defined tools impact key areas of the reporting process slowing efficiency,
increasing risk, and making it difficult to audit reporting.
CORE WORKFLOWS AND REQUIREMENTS SUPPORTING WORKFLOW
AND REQUIREMENTS
Security / Audit / Control
Investigation and
Analytics
Sourcing and Validation AdjustmentsData Management TransformationsReconciliation Report Preparation
CannedEntitlementsData Sourcing Controls TransactionMetadata Management Formulas Drill Down
Data Masking Capital ManagementTechnical Aggregated
Capital Thresholds and
Materiality
Quality Assurance
Report Changes and
Maintenance
Internal
Quality ControlExternal
Ad HocBusiness Derivation Rules Regulatory Thresholds
SOX PerformanceData Accuracy Aggregation Rules Escalation Criteria
Operations MarketRule Confirmation Escalation Tracking
Retention and Archiving Operational DashboardManual UploadLineage and Traceability Error Resolution
RiskModel Approval
RCSAControls
Model Definition and
Enhancement
Break Thresholds
Versioning DerivationsResolution
Restatement
Data Quality Pro Forma
ControlsAdjustment ApprovalData Approval Cross Report
Metrics
Model Governance
Security ReportsSourcing Adjustment InventoryData Governance Calculations
Mapping to General
Ledger
Data Mapping
Validation Rules Research Variance Commentary
AuditDatasets Report Submission
AnalyticsException Tracking Aggregation Attestation
Policy and ProceduresCapital Results Narrative
Copyright © 2017 Accenture. All rights reserved. 5
6. ACCENTURE REGULATORY
REPORTING OFFERINGS
Accenture has developed a set of seven key regulatory offerings to tackle current challenges
in the regulatory reporting space.
Copyright © 2017 Accenture. All rights reserved. 6
DESCRIPTIONVALUEPROPOSITION
Regulatory
Reporting
Dashboard
Standard dashboard
components measuring
the effectiveness of data
processing and
measurement of data
improvement over time.
User Defined Tool
Assessment
Approach
Develop an approach
for the assessment
of manual tools for
determining a tactical
and strategic
elimination strategy.
Integrated
Reporting Tool Set
Implementation
Framework outlining
the standard process,
capabilities, and
technology components
required to streamline
reporting and centralize
finance data for straight
through processing.
Data Quality
Management
Develop standard data
quality management
operating model
(framework) for the
identification,
investigation, and
resolution of data
quality issues.
Capability Design
& Data Sourcing
Development and design
reporting processes and
capabilities. Document
key steps for data
processing, populating
reports and collecting
key reporting data
attributes.
Target Operating
Model and
Governance
Create target operating
model and governance
structure for regulatory
reporting capability to
allow for clear roles
and responsibilities,
ownership, process
documentation, and
governance.
Regulatory
Reporting Vendor
Implementation
Support the client’s
implementation of
regulatory reporting tools
through vendor selection,
business/ functional
requirement gathering,
tool configuration, and
testing/go live support.
• Increase automation
• Improve report
accuracy
• Improve data quality
• Reduce time to
change
• Reduce manual data
• Increase automation
• Improve report
accuracy
• Improve staff usage
• Reduce manual data
• Increase automation
• Improve report
accuracy
• Improve staff usage
• Reduce manual data
• Improve data quality
• Improve report
accuracy
• Improve data quality
• Reduce regulatory
actions
Improve governance
• Increase data
oversight
• Reduce risk
• Improve time
to report
• Increase ownership
• Improve governance
• Reduce redundant
processes and
controls
• Increase automation
and functionality
• Improve report
accuracy
• Reduce manual
controls
7. • Manual tools used to support the
reporting process
• Microsoft Excel® spreadsheets,
Access databases commonly
used for UDTs
USER DEFINED TOOLS
WHAT IS A USER DEFINED TOOL?
• Potential user errors
• Inaccurate reporting
• Inefficient slow process
• High overhead (labor costs)
• Manage manual process
and workflow
• Information sourcing and storage
• Development of reports
Copyright © 2017 Accenture. All rights reserved. 7
User defined tools (‘UDT’) can lead to manual intervention into the regulatory reporting process.
There are multiple drivers to help reduce the number of tools and to create structure around
retained tools to manage ongoing risk.
FUNCTIONSDEFINITION ON GOING COST
8. USER DEFINED TOOLS
IMPACT OF MANUAL DATA MANIPULATION
Copyright © 2017 Accenture. All rights reserved. 8
Our experience indicates the manual manipulation of data often impacts
Operational Risk and Data Accuracy.
~50%
OPERATIONAL
RISKS
• Slow processing due to
manual nature and large
number of user defined tools
• Lack of contingency
planning resulting from
resource turnover
~20%
PRODUCTIVITY
• High cost to produce reports due
to extended processing time
~30%
DATA ACCURACY
AND VISIBILITY
• Manual intervention increases risks
• Lack of transparency in data requirements
• Traceability factor
• Difficult audit trail to trace data quality
9. USER DEFINED TOOLS
APPROACH TO EVALUATE UDTs
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UDT assessment consists of three phases: develop inventory of tools, understand functionality
of each tool, and determine how each tool’s functionality should be provided in the strategic state.
DEFINITION
IDENTIFICATION DECOMPOSITION MIGRATION STRATEGY
• Utilize developed methodologies to
identify the inventory of UDTs and
prioritize them by business impacts
• Decomposition of prioritized UDTs
to understand current functionality,
requirements, and determine
sourcing gaps
• Based on the decomposition analysis
of UDTs identify tactical (quick wins)
and strategic solutions for permanent
elimination
• Identify UDTs used on reports and
schedules
• Determine product impact
• Develop UDT inventory for review
• Prioritize inventory for review
• Decompose UDT functionality and
document associated workflow
• Document data attributes
• Outline data transformations
• Review data sourcing for UDT
elimination or retention
• Determine UDT materiality and
business impact
• Identify tactical solution for sourcing
data gaps
• Develop strategic solution for
UDT reduction
• UDT inventory
• Prioritization metrics
• Workflows
• Critical attributes list
• Non-critical attributes
• Data sourcing analysis
• Tactical elimination plan
• Strategic elimination plan
ACTIVITIESDELIVERABLES
10. PURPOSE / USE
REGULATORY
OPERATIONAL
INFORMATIONAL
USER DEFINED TOOLS
IDENTIFICATION AND CLASSIFICATION OF UDTs
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The identification phase helps develop an inventory of UDTs and classify them based on the
function, the purpose and use, and the criticality of each tool.
Identification Decomposition Migration Strategy
REPORTING FUNCTION
Required for the remediation of a regulatory response
(e.g. MRIA or reporting functionality) • Financial impacts
• Regulatory response (e.g.)
FINANCERISKANALYTICS
Impacts to critical components of the process
(e.g. reconciliation or approval)
• Data errors
• High operational risk
• Data accuracy
Informational tools used for investigative or analysis purposes
with little to no impact to regulatory or operational implications
• Data investigation
• Business analytics
HIGH
MEDIUM HIGH
LOW MEDIUM
UDT Classification
LEVELOFCRITICALITY
11. USER DEFINED TOOLS
COMPONENTS OF DECOMPOSITION ANALYSIS
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For each UDT identified, a detailed analysis should be performed to understand the functionality, data
requirements, data mapping, and identify any potential gaps to be addressed in the strategic state.
Identification Decomposition Migration Strategy
MIGRATION
STRATEGY
• Document UDT purpose and
specific populated reports
• Identify impacted technologies
• Document user defined
tool workflows
FUNCTIONALITY
• Outline report aggregations, data
calculations, and derivations
• Identify data requirements used
within the workflow
• Inventory data by product
• Enhance data attributes by purpose,
timing, available sources, straight
through processing, etc.…
DATA REQUIREMENTS
• Confirm that documented
logic/transformations are accurate
• Validate data availability from
identified source systems
• Map data aggregations, calculations,
derivations, and requirements to report
DATA MAPPING
• Document sourcing gaps (manual data)
• Review system capabilities to
incorporate the functionality and
requirements of user defined
tools for elimination
• Document the business
impact of the user defined
tool and cost to eliminate
GAP ANALYSIS
PROCESS
• Pre-defined process documentation
• User defined tool classification methodology
ACCELERATORS
COLLECTION METHODS
• Developed approach for sourcing
requirements
PRIORITIZATION
• Gap assessment methodology
• Pre-defined rating criteria
12. USER DEFINED TOOLS
PRIORITIZATION METHODOLOGY – ILLUSTRATIVE
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Each UDT should be prioritized based on business impact and ease of elimination criteria in order
to identify candidates for elimination in the tactical and strategic state.
Identification Decomposition Migration Strategy
UDT RATINGS BASED ON CRITERIA02
ID DEFINITIONS REGULATORY FINANCIAL PROCESS
BUSINESS
IMPACT
A1 T1 Verification High High Medium High
B1 Data Validation Medium Medium Medium Medium
C2 Pricing Macro High High Medium High
DEFINING PRIORITIZATION CRITERIA01
Business
Impacts Regulatory Financial Process
Ease of
Elimination Complexity
Cost to
Eliminate
Technology
MediumLow HighRating Criteria
Impact
PRIORITIZE BASED ON RATING03
RATING DESCRIPTIONS (CAN BE QUALITATIVE OR QUANTITATIVE)
HIGH: Regulatory or
severe impact to business
operations and requires
a high cost, long term
elimination effort.
MEDIUM: Financial
impact to business
operations and high cost
to eliminate UDT.
LOW: Process impact
requiring updates to
current technology.
Ease of Elimination
Low
High Low
High
Tactical and
Quick Wins
Strategic
A1
F1 C1
D1 B1
E1
COMPLEXITY
COST TO
ELIMINATE
TECHNOLOGY
EASE TO
IMPLEMENT
High High High High
Low Low Medium Low
Medium Medium Low Medium
13. USER DEFINED TOOLS
TACTICAL AND STRATEGIC ELIMINATION PLAN
TACTICAL SOLUTION STRATEGIC SOLUTION
Practical solutions that are utilized in the interim until a strategic
solution is developed. “Quick wins” and not a means to an end.
Solutions with a concrete and sustainable long- term impact.
The elimination plan details which tools can be removed, consolidated, or rationalized in the tactical
state as well as identify the enhancements required to the strategic tools.
Stale Tools
1
Consolidate Existing Tools
2
Rationalize Existing Tools
3 Develop new technology
Incorporate into
existing technology
Define new data
sourcing methods
Retain low impact tools
4
5
6
7
Identification Decomposition Migration Strategy
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14. USER DEFINED TOOLS
MAINTAINING STRATEGIC UDTs
For UDTs that exist in the strategic state, external vendor tools provide functionality that helps
manage risks, automates data, compares data and facilitates UDT consolidation.
PROCESS
• Investigation and analytics
• Easily tracks changes
• UDT comparison
AUTOMATION
• Elimination of repetitive actions
• Efficient use of resources
• Improve business operations flexibility
UDT CONSOLIDATION
• Ease of use
• Ease of implementation
• Quick analysis
MANAGING RISKS
• Quickly scan spreadsheets to
understand potential risks and errors
• Monitor and manage spreadsheets
• Data integrity
RETAINED
USER
TOOLS
INVENTORYWORKFLOWMANAGEMENT
CONTROLSROBOTICSENABLEMENT
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Identification Decomposition Migration Strategy
15. USER DEFINED TOOLS
ACCELERATORS
Accenture’s previous experience with elimination planning and UDTs has resulted in many
accelerator tools and capabilities to help quickly organize and execute.
ENTERPRISE
PERFORMANCE
MANAGEMENT
Provide an assessment of an
organization's UDTs against
preferred practices.
UDT DECOMPOSITION
PROCESS
Identification of core dimensions
across the “user to analysis”
functionality.
TACTICAL AND
STRATEGIC MIGRATION
METHODOLOGY
Tactical and strategic architecture
developed to improve governance
and overall costs.
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16. THANK YOU
To find out more:
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https://www.accenture.com/us-en/service-regulatory-
remediation-compliance-transformation
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17. LEGEND
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CFPB: Consumer Financial Protection Bureau
CFTC: U.S. Commodity Futures Trading Commission
ESFS: European System of Financial Supervision
FDIC: Federal Deposit Insurance Corporation
FHFA: Federal Housing Finance Agency
FINRA: Financial Industry Regulatory Authority
FRB: Federal Reserve Board
MRIA: Matters Requiring Immediate Attention
NAIC: National Association of Insurance Commissioners
NCUA: National Credit Union Administration
OCC: Office of the Comptroller of the Currency
RCSA: Risk Control Self Assessment
SEC: U.S. Securities and Exchange Commission
SOX: Sarbanes-Oxley Act
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ownership of such trademarks by Accenture and is not intended to represent or imply the existence of an association between Accenture and
the lawful owners of such trademarks.
Accenture, its logo, and High Performance Delivered are trademarks of Accenture.
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DISCLAIMER
This presentation is intended for general
informational purposes only and does not take
into account the reader’s specific circumstances,
and may not reflect the most current
developments. Accenture disclaims, to the fullest
extent permitted by applicable law, any and all
liability for the accuracy and completeness of the
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