There are significant changes due to the implementation of international regulations under BCBS 239 in which the Basel Committee formulated the principles for the effective aggregation of risk data and the risk reporting. They are transposed in MaRisk GP 4.3.4 “Data Management, Data Quality and Aggregation of Risk Data” and are to be implemented by all systemic, German institutions. By October 2020, they are obligated to implement the requirements for data governance (definition of principles with regard to data management, data quality and risk data aggregation, full documentation of processes and data flows) and data architecture and IT infrastructure (e.g. specification of roles and responsibilities, adequate controls during the entire data cycle, high degree of automation). Furthermore, it is necessary to ensure the ability to properly collect risk data in light of the principles of precision, completeness, integrity, updating and flexibility. The MaRisk module SP 3 “Requirements for Risk Reporting,” which contains the content and procedural requirements for risk reporting, must be implemented by all banks by October 2018.
FAS Support in the Implementation of MaRisk
In the implementation of MaRisk, the principle of dual proportionality must be observed. It says that both the individual design and the regulatory review of implementation are oriented to the size and the risk profile of a credit institution. Based on this criteria, FAS AG provides support for the introduction and optimization of individual MaRisk modules and draws up reasonable solution packages geared for the size of the institution and its complexity. Depending on the requirements, the spectrum of services ranges from a comprehensive GAP analysis to the individual implementation of sub-modules. Particularly in the area of the risk bearing capacity calculation, the controlling of liquidity risks or as part of the implementation of new tools for risk reporting, FAS AG has sophisticated methodological knowledge and implements it with consideration given to the framework conditions specific to the institution in each case.
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