Transforming data collection communication to firms – 8 December 2021

View from the director’s’ office

Reflections on the programme so far

Firstly, we would like to thank everyone involved, and congratulate them on what they have done so far. Getting a programme up and running of this size and complexity is difficult. To do it by bringing together people from over 40 different organisations is a big achievement. We think that diversity will be a great strength for the programme moving forward.

Secondly, it’s exciting to see the early outputs from the work. Even at this early stage we can see the right foundations are being built for this decade long transformation journey. We note that issues identified by the programme chime with previous work on data collection. In a similar vein, it’s great to see the variety of solutions being developed: including a combination of small, tangible ‘quick wins’ emerging, alongside longer term strategic solutions.

What we are excited to see in the coming months.

Despite the great progress, we know there is still a lot of work for us as a team to do before the phase one ‘design and discovery period’ ends in March 2022. During that time, there are three things we encourage the team to keep in mind:

• Be ambitious and take risks. Don’t forget this is the first step in a 10 year transformation programme. These early use cases are the space to explore what true transformation means in practice.
• Design solutions in depth. The more specific the design of the solution, the more confidence, we and others, will have to invest in it further.
• Build business cases. Whether or not we, or others in industry, decide to develop a solution will rest on the business case. For any given solution, we will want to see estimates of the value of that solution to a specific use case, its value to the programme as a whole, and, of course, how much you think it will take to deliver it.
• And finally, for those from industry that are thinking about participating, remember, this is your chance to tell us how to make data collection less burdensome. We are listening and welcome your input, however little or much you wish to participate. Email TDCSecretariat@bankofengland.co.uk to get involved.

Transforming Data Collection joint transformation programme - achievements since September 2021

Progress/outputs

The joint transformation programme thinks the issues that industry and regulators face with data collection can be summarised in three key questions:

• How can we ensure our data collections are worthwhile and valuable exercises for regulators and industry to invest in?
• How can industry best understand and interpret our reporting instructions so that high quality data is provided?
• How can we remove legacy data, process and technology siloes and streamline the reporting process?

The joint transformation programme is taking a use case approach in this work to research, design and test solutions to address the issues the regulators and industry face. The three use cases for 2021/22 are:

• The Quarterly Derivatives Return (DQ) – a Bank of England return
• Commercial Real Estate (CRE) reporting – a Bank of England return
• The Covid-19 Impact survey focussing upon the Financial Resilience (FRS) elements – an FCA data collection

Initially the joint transformation programme had planned to have four use cases for 2021/22. The Liquidity Monitoring Metrics (LMM) tool use case was postponed from this phase due to a lack of resources. The reporting transformation committee took the decision to prioritise the programme resource on the other three use cases.

There has been good progress made on the three use cases. The programme team has identified a range of challenges in the areas of data standards and reporting instructions, as well as the difficulties end users have accessing and using the data to make decisions and/or manage risk. They are now in the alpha solution design phase where they are designing and testing solutions and features to tackle priority issues.

A status report of the key activities that have already been undertaken and are still to be delivered is below.

Input to solution design

The design process in the programme team is collaborative, and they wish to engage all stakeholders with relevant knowledge and expertise in areas that relate to our use cases. They are asking for input from vendors and others, to help design potential solutions to challenges they have identified for the use cases. They are currently requesting submissions for the Quarterly Derivatives return (DQ) and Commercial Real Estate (CRE) reporting use cases. The request for input and further information can be found on the Transforming data collection – request for input to the solution design for our use cases page. The deadline for submissions is COB Friday 10 December.

Planned Activities for Early 2022

• In Q1 2022 they will have moved from the ‘discovery’ stage to ‘design’ stage for all phase one use cases. In the ‘design’ phase the programme will explore and design solutions to address the challenges identified in the discovery phase. They will decide which solutions they think we, and industry, should take forward for further investment and implementation. We will also, in consultation with industry, select and confirm the use cases for the next phase.
• Our approach to scaling based on the outcomes of phase one will be a key focus for next year. The Data Standards Committee plans to commission a review on data standards, as the critical reform needed to transform data collection is the definition and adoption of common data standards.
• We will communicate more frequently, sharing timely insights and outputs from the programme. We will explore different channels to engage with our stakeholders.

Update to future budget/resource requirements from industry

This is an update to the communication we published in September on resource requirements. The key changes and industry requirements are highlighted in bold.

We currently have resource commitment from our Joint Transformation Programme participants for the ‘discovery and design’ stage of the first use cases – ending March 2022. We expect we will require industry resource to progress the work beyond March 2022. We expect resource will be required for a number of activities. Below is a table of our requirements for each of the activities followed by a more detailed overview.

Table of requirements/asks:

Progress existing use cases and solutions

To help organise and deliver planned activities for early 2022, we hope as many of the current programme participants as possible can stay on from March 2022 to July 2022. This will enable us to progress the existing work to plan and ensure the transition to the next group of use cases is as smooth as possible.

Testing of BoE / FCA external facing solutions

From July 2022 to June 2023, we aim to move to the ‘delivery’ stage of our phase one use cases. We expect to draw upon the designs and lessons learnt from the joint transformation programme as we invest in our data collection solutions and platforms, and as we plan the future activities and roadmap for transforming data collection. Some of those solutions and platforms have strong external facing elements (such as the FCA/Bank RegData solution, the Handbook, and the reporting sections of the FCA/Bank’s public website). We expect to ask for help from firms in testing our external facing solutions and gathering their feedback as we develop them. We will be looking to form a group of industry users to do this. We expect that group will consist of individuals that actively use those platforms, and they will need to contribute 2 days a month of their time for a 12-month period from July 2022 to June 2023.

Development of solutions

Other solutions are likely to require the development and adoption of industry data standards. These standards will require governance, platforms tooling, training, and people to manage and support these standards as a service. We will need applications that show how standards can be used and add value to their users. We expect to ask industry to contribute to this initiative. We expect we will require a total of around £2,000,000 in voluntary contributions from industry for solution development.

Joint Transformation Programme innovation new use cases

From June 2022 to March 2023, we expect the joint transformation programme to carry out a ‘discovery and design’ stage for a new set of use cases. We expect these use cases to be more complex and higher value than the use cases in scope of the current phase. To enable us to continue with our ‘discovery and design’ work for new use cases, we will be asking firms to provide twice the levels and types of resource to the delivery teams as they do currently – around 20 FTE for the core delivery team. These FTE will focus on discovery and design/ prototyping activities and will allow us to scale the approach and deliver more value faster. The key skills we expect to require are Business Analysis, Service Design, User Research, and Data Management, as well as SMEs in compliance and areas specific to the new use cases.

Consider internal initiatives to maximise benefits of the Joint Transformation Programme

In 2022, and during the course of the programme, firms and reporting solution providers may wish to consider what internal initiatives they want to run to maximise the benefits of the joint transformation programme. For instance, these initiatives may relate to further developing and rolling out solutions designed by the programme; or may relate to planning and budgeting activities for future phases of the programme and wider work on transforming data collection. We also know that some firms are now investing in significant initiatives to improve their data management.

We do not expect our work on Transforming Data Collection to trigger any mandatory change which will require firm implementation in 2022.

We recognise firms need to have greater clarity on the future phases and resource needs of the joint transformation programme and transforming data collection work. The next steps for the BoE and FCA are to develop a roadmap for how we take the Transforming Data Collection initiative forward. We expect to have the first version of the roadmap defined and shared with industry by the middle of 2022.

Future joint work programme communications and updates 

To ensure we continue to work with industry in an open, collaborative and transparent manner, we will be providing regular programme updates to not only share our outputs, but to provide opportunities to be involved with our work and to give feedback. Next year we anticipate providing programme updates at least every two months.

All of our communications and updates will be published on the Transforming Data Collection webpage.