The 3 Little Architects and the Big Bad Mr. Wolf – A Data Parody for today’s Financial Industry
Once upon a time, there were 3 Information Architects working in the financial services industry, each with different firms and backgrounds but all responsible for recommending the right technology solutions to help their firms comply with industry regulations including ongoing bank stress testing across the globe. Since 2008, bank regulators have been focused on measuring systemic risk and requiring banks to provide transparency into how risk is measured and reported to support their capital adequacy needs.
The first architect grew through the ranks starting as a Database Administrator, a black belt in SQL and COBOL programming. Hand coding was their DNA for many years and thought of as the best approach given how customized their business and systems were vs. other organizations. As such, Architect #1 and their team went down the path of building their data management capabilities through custom hand coded scripts, manual data extractions and transformations, and dealing with data quality issues through the business organizations after the data is delivered. Though their approach and decisions delivered on their short term needs, the firm realized the overhead required to make changes and respond to new requests driven by new industry regulations and changing market conditions.
The second architect is a “gadget guy” at heart who grew up using off the shelf tools vs. hand coding for managing data. He and his team decides not to hand code their data management processes, instead adopt and built their solution leveraging best of breed tools, some of which were open source, others from existing solutions the company had from previous projects for data integration, data quality, and metadata management. Though their tools helped automate much of the “heavy lifting” he and is IT team were still responsible for integrating these point solutions to work together which required ongoing support and change management.
The last architect is as technically competent as his peers however understood the value of building something once to use across the business. His approach was a little different than the first two. Understanding the risks and costs of hand coding or using one off tools to do the work, he decided to adopt an integrated platform designed to handle the complexities, sources, and volumes of data required by the business. The platform also incorporated shared metadata, reusable data transformation rules and mappings, a single source of required master and reference data, and provided agile development capabilities to reduce the cost of implementation and ongoing change management. Though this approach was more expensive to implement, the long term cost benefit and performance benefits made the decision a “no brainer’.
Lurking in the woods is Mr. Wolf. Mr. Wolf is not your typical antagonist however is a regulatory auditor whose responsibility is to ensure these banks can explain how risk is calculated as reported to the regulatory authorities. His job isn’t to shut these banks down, instead making sure the financial industry is able to measure risk across the enterprise, explain how risk is measured, and ensure these firms are adequately capitalized as mandated by new and existing industry regulations.
Mr. Wolf visits the first bank for an annual stress test audit. Looking at the result of their stress test, he asks the compliance teams to explain how their data was produced, transformed, calculated, to support the risk measurements they reported as part of the audit. Unfortunately, due to the first architect’s recommendations of hand coding their data management processes, IT failed to provide explanations and documentation on what they did, they found the developers that created their systems were no longer with the firm. As a result, the bank failed miserably, resulting in stiff penalties and higher audit costs.
Next, Architect #2’s bank was next. Having heard of what happened to their peer in the news, the architect and IT teams were confident that they were in good shape to pass their stress test audit. After digging into the risk reports, Mr. Wolf questioned the validity of the data used to calculate Value at Risk (VaR). Unfortunately, the tools that were adopted were never designed nor guaranteed by the vendors to work with each other resulting in invalid data mapping and data quality rules and gaps within their technical metadata documentation. As a result, bank #2 also failed their audit and found themselves with a ton of on one-off tools that helped automate their data management processes but lacked the integration and sharing of rules and metadata to satisfy the regulator’s demand for risk transparency.
Finally, Mr. Wolf investigated Architect #3’s firm. Having seen the result of the first two banks, Mr. Wolf was leery of their ability to pass their stress test audits. Similar demands were presented by Mr. Wolf however this time, Bank #3 provided detailed and comprehensive metadata documentation of their risk data measurements, descriptions of the data used in each report, an comprehensive report of each data quality rule used to cleanse their data, and detailed information on each counterparty and legal entity used to calculate VaR. Unable to find gaps in their audit, Mr. Wolf, expecting to “blow” the house down, delivered a passing grade for Bank 3 and their management team due to the right investments they made to support their enterprise risk data management needs.
The moral of this story, similar to the familiar one involving the three little pigs is about the importance of having a solid foundation to weather market and regulatory storms or the violent bellow of a big bad wolf. A foundation that includes the required data integration, data quality, master data management, and metadata management needs but also supports collaboration and visibility of how data is produced, used, and performing across the business. Ensuring current and future compliance in today’s financial services industry requires firms to have a solid data management platform, one that is intelligent, comprehensive, and allows Information Architects to help mitigate the risks and costs of hand coding or using point tools to get by only in the short term.
Are you prepared to meet Mr. Wolf?