Regulatory Reporting

Client: Leading Investment Bank

Challenge

• The client asked Charles Alan to provide advisory support for the T+2 project, which seeks to implement changes to its 2052a reporting so that it can be produced on a daily T+2 basis.
• Additionally, the 2052a report would have to be implemented to comply with Category III 2052a reporting requirements as outlined by Reg YY. The project focused on completing the testing of implemented initiatives.
• Following the initial review of existing processes, the Client asked Charles Alan to implement a comprehensive transformation of the Bank’s regulatory reporting function, including the establishment of a control framework, development of governance and accountability disciplines (across data and processes), and the automation of the regulatory reporting process.

Approach

• Interpreted Fed guidance for FR2052a Inflow/Outflow and Supplemental tables and provide solutions to the client for any gaps in reporting
• Developed Proof of Concept for Liquidity reporting methodology to ensure consistent reporting of FR2052a transactional level data to US Federal Reserve
• Worked with stakeholders in Treasury, Audit and Liquidity Risk to remediate and resolve any MRA/MRIA’s aka Matter Requiring Attention/Immediate Attention raised by US Federal Reserve related to Liquidity Reporting
• Created solutions with Technology & Operations teams to streamline variance analysis and commentary processes for FR2052a LCR/NSFR submissions
• Assisted the Liquidity Measurement & Reporting team in ensuring that appropriate variance checks are in place for daily T+2 reporting and LCR/NSFR XML submissions on a T+15 basis.

Results

• Successfully accelerated the delivery within 9 month timeframe to remediate numerous MRAs with the implementation of new and enhanced controls and processes, new attestations, and system implementations, covering both vendor and in-house developed.
• Enhanced and automate regulatory reporting processes using new technologies/platforms including Axiom, Wdesk, Alteryx, Qliksense thereby eliminating/reducing manual adjustments.
• Automated control checks and strengthen existing rules & procedures across the liquidity reporting stack to ensure minimal error rate in regulatory submissions.

Client: Tier 1 Investment Bank

Challenge

• Charles Alan was asked to advise and oversee the roll out the new KYC Key Operating Processes (KOP) to the US, UK and Germany. This involved large scale changes in processes and training for over 1000 employees across the organization globally.

Approach

• Created the Project Initiation Document (PID) and set up the governance requirements in line with initiative standards.
• Established weekly Status Report including risks, issues, achievements, L0 & L1 milestones etc.
• Developed training material and rolled out to over 1000 employees globally.
• Producing weekly MI on training deployment.
• Extensive engagement with Stakeholders via status meetings held on a monthly or fortnightly basis depending on the timeframe to go live, these included deep dives e.g. technology changes, process flows, new requirements etc.
• Facilitating approvals across Anti Financial Crime (AFC) and for the US Local Addenda and its operationalization.
• Support drafting Self-Identified Issues (SIIs) to cover the known gaps from KYC Policy, as it was agreed a phased approach would be used to roll out all elements of the policy through the KYC KOP, final deployment. 

Results

• Successfully rolled out the new KYC KOP and training across the organization, achieving all deliverables and agreed timeframes.

Client: Tier 1 Investment Bank

Challenge

• Due to new OCC requirements the Client instructed Charles Alan to lead the development of an AML Customer Risk Rating system.

Approach

• Developed OCC-Compliant AML Customer Risk Rating system that captures, evaluates and monitors risk for new customers prior to onboarding for commercial Lending, Consumer Lending and Wealth Management
• Project managed the creation of AML CRR system that allows branch users to collect characteristics about the client, product, and geography and submit to EDDO user and manager for review and approval

Results

• Created OCC customer risk rating report that weighted and scored the entire customer information producing a final customer risk report with scores of high, medium or low risk.
• Developed process flows for new account opening due diligence procedures that handle entity and non-entity accounts
• Successfully managed SDLC & implemented regulatory requirement projects AML CRR, FATCA, ACH, etc. 

Client: Tier 1 Investment Bank

Challenge

• Delivery and implementation of Global KYC and Client On-Boarding polices in 38 countries across Global Market, Asset Management and Corporate and Investment Banking. 

Approach

• Initiated and led reviews and reconciliation of KYC systems to trading systems across all 38 countries. 
• In-country implementation and remediation of historical KYC files
• The team worked in partnership with Regional and Country management, Compliance, Technology, Operations and the Business. 

Result

• Delivered an enhanced KYC capability through a new KYC governance model, key operating  procedures, risk based MI, training and quality assurance.