Three ways out of the minimal viable compliance trap
Roy Kirby, SIX Financial Information, Senior product manager, London, 16 March 2018
The practice of settling for 'minimum viable compliance' might work to some degree, but it is always eventually self-defeating.
When major regulatory deadlines are around the corner, the financial industry inevitably tends to respond by scrambling for minimum viable compliance. Put simply, this means doing whatever it takes, regardless of the expense, just to keep the regulator at bay. This approach may work in the short term, but it is unlikely to stand the test of time when future requirements appear and costs inevitably shoot up.
This is why, as two months on from the implementation of MiFID II, financial institutions need to take swift steps to ensure that their data is in line with all recent regulatory changes. This boils down to three categories: consistency, quality and co-operation.
Consistency
The first step for anyone who wants to achieve sustainable long-term compliance should be an obvious one. It is not affordable to keep adding to a vast array of information, already housed in many systems, every time the financial firm has to obey a new rule. If a firm tries to solve each data-related problem with a new approach, this will only cause more compliance headaches. It needs a consistent form of information housed in one location that its compliance people find easy to access.
Once you your data is housed in one central hub and further regulatory changes come, you will not only have an accessible and clear source of data; you will also be able to cross-reference the data in that hub. This can be a crucial time-saver – especially in view of the crossovers between many of the regulations.
Quality
Once national regulators are receiving fairly consistent data from financial firms, their focus will inevitably shift to the quality of the data they are receiving. Firms that are sending data full of mistakes (such as inaccurate pricing) will be penalised.
As a result, once the noise has died down on the subject of consistent data, we can expect firms to start trying to work out what more they can do with their reference and market data. Firms that are ahead of the game in providing or finding excellent sources of information are likely to have a competitive advantage.
Co-operation
January’s regulatory changes have completely transformed the way in which firms must exchange information between each other. For example, manufacturers of financial products are having to think in much more detail about how to send out data and documents to their distributors. Both manufacturers and distributors also ought to look at how they share information related to sales outside their target markets.
If you are finding it hard to adjust, you ought to realise that other firms in your vicinity are probably having the same problems. With this in mind, your natural next step is to look at mutualised approaches to your problems, with firms helping each other to gather the required information together. Firms that are having to cope with today's regulatory onslaught should be challenging their data partners to provide exactly what they need right across the business, in the forms in which they need it. The time has come for data that is, in the common phrase, "ready to consume."