BCBS 239 principles

The Basel Committee published the principles on 9 January 2013. The crisis that began in 2007 had shown that many large banks were unable to aggregate their risk exposures and spot concentrations fully, quickly and accurately. The principles address global systemically important banks, and national supervisors may apply them to domestic systemically important banks as well.

Risk data aggregation means defining, gathering and processing risk data according to the bank's reporting needs, so it can measure its performance against its risk appetite. Banks designated as global systemically important by November 2012 had to comply from 1 January 2016.

The standard has 14 principles. Two cover overarching governance and infrastructure: the board and senior management own the data framework, and the data architecture and IT infrastructure must support aggregation in normal times and under stress. Four cover aggregation capabilities: accuracy and integrity, completeness, timeliness and adaptability. Five cover risk reporting: accuracy, comprehensiveness, clarity and usefulness, frequency, and distribution. Three are addressed to supervisors, on review, remedial action and cooperation.

The principles do not prescribe a technology. They describe outcomes, so two banks can comply with very different architectures, as long as each can show the outcome when a supervisor tests it.

The European Central Bank consulted on a guide on effective risk data aggregation and risk reporting from July to October 2023. The ECB guide names seven areas: the responsibility of the management body, the scope of the data governance framework, roles and responsibilities for data governance, a group-wide integrated data architecture, effective data quality controls, timely internal risk reporting, and implementation programs. The ECB wrote that adequate capabilities in this area were still the exception, after a 2016 review of 25 significant banks had found serious weaknesses.

Deloitte reports high-severity findings in inspections and notes that risk data aggregation sits among the supervisory priorities of the ECB. For banks that BaFin supervises, MaRisk asks in AT 7.2 for effective processes that secure data quality for the material risk types, and in AT 4.4.1 for unrestricted access of the risk control function to all risk data it needs.

The 14 principles cover governance (1) and data architecture and IT infrastructure (2); accuracy and integrity (3), completeness (4), timeliness (5) and adaptability (6) of aggregation; accuracy (7), comprehensiveness (8), clarity and usefulness (9), frequency (10) and distribution (11) of reports; and supervisory review (12), remedial actions (13) and home and host cooperation (14).

The principles target systemically important banks, and the ECB applies its guide to the significant institutions it supervises. Smaller German banks meet the same questions in a lighter form through MaRisk, whose rules on data quality and risk reporting apply to every institution.

Lineage is the documented path of a number from its source system through every transformation to the risk report. Without it a bank cannot show that a figure is accurate and complete, which is why supervisors ask for it when they test the aggregation principles. Data lineage is also the part where data engineering and risk management have to work on the same model.