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Leveraging XBRL for Basel II Daniel D’Amico, IBM Business Consulting Services, UK Agenda Basel II background Basel II is an opportunity The data management challenge XBRL and Basel II A couple of quotes “Regulators and customers are demanding greater focus on risk management. …This call for transparency will challenge traditional business practices and will require more auditable processes throughout the business” Morgan Stanley analyst (on market timing), FT 11/03 “US regulators expect Basel II will apply to a total of around 20 large US banks. All US banks operating under Basel II will be obliged to use only the most advanced Basel II approaches for assessing banking risks, which means the IRB approaches in the case of credit risk.” Global Risk Regulator 10/03 Basel II Background What is Basel II Accord? What is it trying to achieve? The publication of the Basel II Accord will mark the end of long process that will have effectively rewritten the rules of banking. Basel II will affect the conduct of monetary policy and the stability of financial institutions all over the world To promote safety and soundness in the financial system To align regulatory capital requirements more closely with underlying risks To offer incentives for institutions to pursue more sophisticated & effective risk management New Accord CP 3 Full force Parallel run Basel I + II Integrate into National law When does it happen? QIS 3 Oct 02 Commercial imperative Evaluation QIS 3 Dec 02 Consultation phase May 03 Preparation New Accord July 03 EU directive Nov 03 Jan 06 Dec 06 Basel II will significantly impact FS institutions and the change is such that preparation needs to begin now to ensure readiness for a parallel run starting 1st Jan 2006 Key strategic decisions need to be taken now on the approach to be taken and the benefit that should be achieved over and above compliance Basel II is an Opportunity – not just a Mandate Basel II Opportunities: Basel II Pillar 1: Minimum Capital requirements Calculation and Management of: Credit Risk Operational Risk Market Risk Pillar 2: Supervisory Review Process Ensure sound processes Ensure adequate capital at all times Ensure motivation improving risk management practices Data Foundation Pillar 3: Market Discipline Quantitative and qualitative disclosure of undertaken risks and risk methodologies • • • • • • Improve shareholder value Economic capital savings Improve/maintain credit rating Improve risk management strategy Alignment of Risk & Finance Cost reduction through organizational process improvement • Identify potentially dangerous portfolio positions and other risk sources Basel II Challenges: • • • • Setting up Basel II program Data management Systems management Establishing Risk Framework Key challenges – Systems & Data Management 10 Common signs of unstable data foundation Data Management is the key challenge in meeting Basel II Source: IBM Institute for Business Value analysis, Banks and Basel II: How Prepared Are They?, October 2002 interviews with 32 Financial institutions worldwide 1. Inability to gather data for new reporting requirements. 2. Difficulty complying with regulatory requirements like Basel II Accord 3. Senior management questions quality, timeliness, reliability of information used to make multi-million dollar decisions 4. Inability to consolidate data from multiple diverse sources 5. Senior Management requests for information require intensive manual effort to respond, and far longer than desired. 6. Difficulty in building a single architecture to address both data consolidation and data aggregation requirements. 7. Multiple databases or spreadsheets storing similar data; no common data “dictionary” across the enterprise 8. No ownership of data 9. There’s no single enterprise view of data 10. Difficulty answering questions about the origins and business processes performed against data A complex International banking group • Capital allocation • Capital Calculation • Risk Strategy • External Reporting Group Private Banking and Asset Management Wholesale Banking Discretionary Portfolio Management Fixed Income, Equity and derivatives Corporate Personal Finance UK retail North America Singapore Credit Cards Asia Pacific Hong Kong Japan Cross Modelling Solution Common definition of LGD, PD, EAD Common customer identifier IBM’s Basel II Architecture Loss Data Data Warehouse Collaterals Extraction, Validation Customer Result Risk Engine Data Basel II Market Risk Engine Basel II Op. Risk Engine Core Banking Products Disclosure Result Data Result Data Group Non-Basel II Result Risk Engines Management Data Data Rating, PD, LGD, Internal Audience CCF Models Extraction External Audience Regulatory Credit Data source Basel II Credit Enterprise Data store Transformation & calculation Metadata Warehouse Administration Data Marts Reporting Where does XBRL fit? 1 XBRL Loss Data Data Warehouse Extraction, Validation Customer Collaterals Basel II Credit Result Risk Engine Data Basel II Market Risk Engine Basel II Op. Risk Engine Core Banking Products Disclosure Data Result Data Group Non-Basel II Result Risk Engines Management Data Data Internal Audience CCF Models 3 External Audience Result Rating, PD, LGD, Extraction XBRL Regulatory Credit Data source 2 Enterprise Data store XBRL Transformation & calculation Metadata Warehouse Administration Data Marts Reporting XBRL for Basel II analytics 1 XBRL Loss Data Data Warehouse Collaterals Extraction, Validation Customer Result Risk Engine Data Basel II Market Result Risk Engine Data Basel II Op. Result Risk Engine Data Non-Basel II Result Risk Engines Data Core Banking Products Disclosure Rating, PD, LGD, Enterprise Data store Transformation & calculation Metadata Warehouse Administration Aggregate data for analytics • Multiple Sources • Different periods • Different rules Data Marts Many Analytics requirements • • • Group Management Data Internal Audience CCF Models Extraction External Audience Regulatory Credit Data source Basel II Credit Reporting • • • • • • • • Credit Risk Profile Credit Risk Assessment Credit Risk Mitigation Assessment Operational Risk Assessment Portfolio Credit Exposure Security Analysis Liquidity Risk Collections Analysis Involved Party Exposure Location Exposure Non Performing Loan XBRL for Basel II reporting 2 Loss Data Data Warehouse Collaterals Extraction, Validation Customer Result Risk Engine Data Basel II Market Result Risk Engine Data Basel II Op. Result Risk Engine Data Non-Basel II Result Risk Engines Data Core Banking Products Disclosure Rating, PD, LGD, Many reporting requirements • Enterprise Data store Transformation & calculation Metadata Warehouse Administration Aggregate data for reporting • Multiple Sources • Different periods • Different rules Group • Management Data Internal Audience CCF Models Extraction External Audience Regulatory Credit Data source Basel II Credit XBRL Data Marts Reporting • External • Disclosures • Regulatory Internal • Group • Subsidiary • Management reporting Integration with other reporting requirements • IAS Common definition using XBRL Loss Data Data Warehouse Extraction, Validation Customer Collaterals Result Risk Engine Data Basel II Market Result Risk Engine Data Core Banking Products Basel II Op. Result Risk Engine Data Non-Basel II Result Risk Engines Data 3 XBRL Transformation & calculation Group Data Marts • • Management Data Internal Audience CCF Models Enterprise Data store Definition of Internal Basel II taxonomies: Disclosure Rating, PD, LGD, Extraction External Audience Regulatory Credit Data source Basel II Credit • Reporting Metadata Warehouse Administration • • Basel II is an opportunity for banks to force its subsidiaries and business units into following a common understanding of data, driving common standards into the organisation . XBRL can be THE standard Define an organizational metadata layer Traceability back to transactions Common repository for changes and updates to requirements Enhance group ability to consolidate data Improve data quality How is XBRL solving some of the data management issues? 1. 2. 3. 4. 5. 6. Inability to gather data for new reporting requirements. Difficulty complying with regulatory requirements like Basel II Accord Senior management questions quality, timeliness, reliability of information used to make multi-million dollar decisions Inability to consolidate data from multiple diverse sources Senior Management requests for information require intensive manual effort to respond, and far longer than desired. Difficulty in building a single architecture to address both data consolidation and data aggregation requirements. Multiple databases or spreadsheets storing similar data; no common data “dictionary” across the enterprise 8. No ownership of data 9. There’s no single enterprise view of data 10. Difficulty answering questions about the origins and business processes performed against data XBRL for Basel II Analytics XBRL for Basel II reporting 7. Common definitions using XBRL Leveraging XBRL for Basel II Daniel D’Amico, London UK IBM BSC, Financial Services Sector, Risk and Compliance [email protected]