2 March 2023

Date of meeting: 2 March 2023 | Location: Bank of England / Microsoft Teams Meeting

Minutes

Reporting Transformation Committee

Item 1. Introduction and Agenda

AS recapped the discussion of the kick off meeting in November. The Secretariat has requested nominations for the role of chair, and had committed to create a forward agenda of meeting for the committee. Following the nominations process, Andrew Turvey had become the committee’s chair.

Item 2. Forecast calendar

AS presented a forecast calendar of discussions throughout phase 2, including projected dates for meetings/workshop, when the programme team expected to present elements of each use case, and when they envisaged the committees might make any recommendations.

AT asked for feedback from the committee on the calendar, and the committee had some scheduling comments, which the Secretariat agreed to factor into plans.

Item 3. Financial Conduct Authority (FCA) Strategic review of Prudential Data Collections

The FCA team working on the review of its prudential data presented their work so far. They explained the purpose and work of the discovery phase. They then presented conclusions from this, which included uncertainty around the purpose of some collections, and short notice requests. Processes are felt to be too FCA-centric.

The presented the opportunities this work had identified, including improving accessibility and clarity of guidance, data input and validation, and data adequacy.

The team explained their next steps - designing a new approach to collecting prudential data, focusing on what data the FCA needs, user-centred design and putting the right tools in place. The team would also decide upon datasets it would use as the basis of this design work.

Key comments and discussion points:

• KW spoke of the need for regulators to be clear about why they need certain data. Members spoke about the balance between regular and ad hoc reporting, with opposing views on how the balance should work.
• Members felt that an additional way to clarify guidance would be operating a Q&A process similar to those run by the EBA/ESMA.
• The FCA explained that data quality issues are driven by unclear guidance – firms are confident in the accuracy of their data, but not whether this meets the FCA’s needs. Guidance allows for various interpretations that could all seem valid.
• Some members felt that problems and solutions discussed were already known from previous TDC work. They emphasised what they felt was the importance of delivering reforms rather than perfect design. LD responded that work in phase 1 was quite tactical, addressing specific problems. She added that the FCA were considering the suitability of the ‘use case approach’ for the next phase of work.
• The FCA and firms agreed that the programme was identifying scalable reforms, which was key to success.

Item 4. Commercial real estate (CRE) data

MT presented an update on the Bank of England's (the Bank) work on the CRE use case. The project had completed its discovery phase, identifying a large number of granular problems which had aggregated into themes. On the firm side these included unclear expectations and high costs for change. On the Bank side this included poor quality data, and dis-alignment between datasets. The project was now in the early stages of design work. 

Key comments / discussion points:

• Some committee members requested that the project solicit firm feedback earlier to ensure the project was also addressing problems on the firm side, in order to avoid missing key issues.
• Committee members reiterated previous comments about the importance of tackling issues around data definitions, and alignment between reporting and disclosure.
• AT encouraged the team to focus on the highest priority problem statements in order to deliver solutions in the coming months.

Item 5. Incident, Outsourcing and Third-Party Reporting (IOREP)

MR updated the committee on the status of the IOREP use case. This project consisted of designing a new data collection, aimed at providing authorities with a better understanding of operational resilience in the financial sector. The project had completed a procurement process to hire external consultants to do the discovery and design work. This would begin soon.

Item 6. Retail Banking Business Models data (RBBMD)

CC recapped the scope of the use case, which had begun work on its discovery phase. The FCA had chosen this use case as it was important data that was collected on an ‘ad hoc basis’ from firms, that was costly to report and inefficient to analyse. Discovery work was due to run until late March, when design work would begin.

Item 7.  Implementation of phase 1 recommendations

The programme team provided updates on the implementation of the Bank and FCA’s reforms from the phase 1 use cases (Form DQ and FRS). 

The Bank had onboarded content designers and user researchers to work, who had developed solutions for a new webpage and were recruiting users for testing. They aimed to have prototypes ready in the coming weeks. 

The FCA had rolled out a new version of its CCR007 report with an intuitive layout and new guidance. It was now measuring the benefits of implementing that. AT remarked that this was the first change that TDC had delivered, and that this was a key milestone.

Item 8. Forward agenda / AOB

AS outlined the activities planned in the coming weeks. Discovery workshops were planned between the committees and the teams working on the RBBM and IOREP use cases. The committee’s next full meeting was planned for April.

Attendees

Richard Adnett (RA), Royal London Group

Loic Boisdron (LB), Financial Conduct Authority

Chris Caldwell (CC), Financial Conduct Authority

Laura Cusack (LC), Financial Conduct Authority

Lauren Dixon (LD), Financial Conduct Authority

Jacqueline Davies (JD), TSB

Dayo Forster (DF), Bank of England

Mike Green (MG), Financial Conduct Authority

Ross Johnston (RJ), Westpac Bank

Sean Lane (SL), Google Payment Limited

Alison Morley (AM), Barings

Derek Paine (DP), Mizuho International

Susannah Parden (SP), Barclays

Robert Pengelly (RP), Nationwide Building Society

Rocco Quartu (RQ), Financial Conduct Authority

Mehroze Ravi (MR), Bank of England

Daniel Sadler (DS), Association of British Insurers

Aaron Shiret (AS), Bank of England

Tammy Solomon (TS), Investec

Rob Thickett (RT), Building Societies Association

Matt Thompson (MT), Bank of England

Andrew Turvey (AT), Belmont Green

Ben Watson (BW), Financial Conduct Authority

Karen Watts (KW1), Financial Conduct Authority

Kenny Wong (KW2), One Savings Bank

Apologies

Nathan Beverley, Pension Insurance Corporation

Rudi Damhuis, Legal and General

Ken Ellis, Clear Bank

Mark Jones, Cambridge and Counties Bank