November 2021

he Board in that transformation.

Key Discussion Points/Comments:

• Members emphasised that reporting is just a process aimed at producing an outcome – delivering data for users at firms and regulators that are gathering information. Members said any changes to the reporting process must improve that outcome.
• Some members emphasised the need for a paradigm shift in how reporting happens. They felt this paradigm shift should allow far greater flexibility in collections. SC described the future reporting process allowing authorities to answer ‘the unexpected question’. Some members described what that future state might look like. They described a world of data residing in curated datasets rather than in reports, with authorities allowed to access that data under specified conditions.
• Other members focussed on the need to streamline what data is collected. PB thought that regulators need to overcome the mindset that there is always benefit from additional data. He felt reporting should be more coherent but more streamlined.
• Members discussed who might be the beneficiaries of a transformation of data collection. SOM stated the importance of considering all relevant stakeholders, particularly market participants, who stand to benefit from increased data transparency.
• Members agreed that a key function of the Board will be holding the Joint Transformation Programme accountable – ensuring it has a clear purpose, achieving its objectives etc.
• Members agreed that the programme needs a clear approach to transforming data collection, based on a set of defined principles. They felt the board had a role to play in defining and publicising these principles. SS mentioned the FAIR Guiding Principles for scientific data management and stewardship as a useful comparison.
• Members commented that the Bank/FCA should further clarify the Board’s remit. They also thought the Board should articulate a vision for the project.
• AM summarised the actions for the programme.

Action: Secretariat to develop a framework for measuring the progress/benefits of the programme.

Action: Secretariat to produce an initial draft of design principles for the programme’s outputs, for the Board’s consideration.

Pre-mortem for Transforming Data Collection and Board

IP asked the Board to imagine that in ten years’ time the programme had failed to achieve a transformation, and suggest what would be likely to have caused this.

Key Discussion Points/Comments:

• Members reiterated their view that work on transforming data collection should have a set of well-defined objectives. They felt these objectives should be measurable and that tracking the programme’s progress against its goals should be based on evidence. They felt a key role of the Board is to define and track these measures. CR2 suggested that the programme could express its objectives as a granular set of goals, rather than as one big ambition. RK suggested that the Board repeatedly redefine these objectives in response to developments.
• Members discussed how to ensure that the scope of the work is both clear and manageable. CR2 suggested that a goal of ‘transforming data collection’ is too broad. He suggested that the programme participants will need to decide on the extent of their ambition for the different elements of the programme. For instance, he felt the Board will need a strong sense of which goals will need ‘transformation’, and which will just need ‘improvements’.
• Members agreed the programme’s focus should be on removing the elements of data collection that create inefficiency, rather than building new collections intended to be more efficient.
• Some members emphasised the need to get firms to ‘buy-in’ and show benefits to firms beyond regulatory reporting. For instance, RA spoke about the need to produce and show benefits to firms beyond regulatory compliance. He felt there are group-wide technology and data benefits from the transformation programme. He felt that excessive focus on regulation would risk isolating the programme from relevant stakeholders.
• AA warned of the costs of regulation and the risk that industry passes this on to customers. He also proposed that the project tracks ongoing developments in relevant technology.

Joint Transformation Programme update

RD1 presented the programme’s conceptual view of how transformation should work – ‘pipeline management’ first, then ‘discovery and design’, ‘decision and challenge’ etc. She explained the different elements of the programme structure, including the roles of the different governance and delivery groups.

AM gave an update on the project plan, including the status of the discovery and design work. He explained that a key element of the plan is work aimed at scaling-up the solutions e.g. when tackling CRE issues, considering whether the solutions emerging may also apply to mortgages.

LA asked for clarification about the relationship between the Board and the rest of the programme. IP suggested that the programme could make this clearer and that the Terms of Reference may be the best way to do this.

Action: Secretariat to consider need for clarification of the ToR and confirm next steps.

Chair nomination process

AM explained that over the longer term, the Board will have a Chair from industry. He explained the process for choosing the Chair. If participants wish to be the Chair, they should nominate themselves. The Board will then vote on the nominees.

Action: Participants who wish to nominate themselves should send a short statement to the Secretariat explaining their suitability by 16 November 2021.

Actions agreed in this meeting

• Members to send any comments on the ToR to Secretariat by 16 November 2021.
• Secretariat to develop a framework for measuring the progress/benefits of the programme.
• Secretariat to produce an initial draft of design principles for the programme’s outputs, for the Board’s consideration.
• Secretariat to consider need for further clarification of the ToR and confirm next steps.
• Participants who wish to nominate themselves should send a short statement to the Secretariat explaining their suitability by 16 November 2021

Attendees

Ankur Agrawal (AA), AXA

Luke Ashton (LA), Barclays

Roshan Awatar (RA), Lloyds Banking Group

Paul Barrett (PB), AIG

Andy Beale (AB), Financial Conduct Authority (Interim TDC Programme Manager)

Paul Chambers (PC), Standard Chartered

Samik Chandarana (SC), JP Morgan

Charlotte Clark (CC), Association of British Insurers

Graham Cohen (GC), BNY Mellon

Rebecca Ding (RD1), Financial Conduct Authority (Transformation Programme Lead)

Richard Dunne (RD2), RSA Group

Lee Fulmer (LF), UBS

Alastair Hall (AH), Legal & General

Rakshit Kapoor (RK), Santander

Shane Kingston (SK), Brit Insurance

Angus Moir (AM), Bank of England (Transformation Programme Lead)

Scott O’Malia (SOM), International Swaps and Derivatives Association

Adrian Pearce (AP), Credit Suisse

Ian Phoenix (IP), Financial Conduct Authority (Director of Intelligence & Digital)

Corinne Powley (CP), Phoenix Group

Elaine Priest (EP), NatWest

Charles Reindorf (CR1), Bank of America

Charles Resnick (CR2), ClearBank

Aaron Shiret (AS), Bank of England (TDC Secretariat)

Simone Steel (SS), Nationwide Building Society

John Tierney (JT), Nomura

Matthew Tyrrell (MT), Financial Conduct Authority (Senior Manager, Central Data Services)

Apologies

Gareth Ramsay, Bank of England (Executive Director of Data & Analytics)

David Palmer-Lewis, Principality Building Society

Andy Parsons, Just Group