12 Common Mistakes to Avoid While Preparing and Filing BSP FRP Reports in the Philippines
Table of content
- Inconsistent and inaccurate reporting
- Lack of documentation
- Incorrect mapping of data
- Lack of transparency
- Insufficient validations
- Inaccurate interpretation of the regulation
- Inefficient data infrastructure
- Adhoc changes in response to regulatory changes
- Unauthorised Report Submissions
- Uncontrolled manual adjustments
- Missed deadlines for submission
- Missing audit trails
- Conclusion
On time, accurate regulatory reporting is a foundational process for financial institutions that impacts the health and vitality of the financial system. Despite being significantly challenge-ridden, financial institutions often overlook the importance of an effective and efficient technology solution for regulatory reporting – one that fits their requirement just right! The lack of strategic thought and myopic approach lead to inadequate budgetary allocations for these solutions as their financial impact is unduly compared with revenue-generating IT projects.
As a result, a patchwork of methods such as transaction processors, spreadsheet macros, manual computations, and emails get implemented as regulatory reporting solutions. This often leads to suboptimal regulatory submissions which can result in regulatory fines, complex time-consuming iterations, reputational damage and loss of trust in the ethos of the organisation.
The Bangko Sentral ng Pilipinas (BSP), the central bank of the Philippines has mandated a comprehensive list of regulatory reports known as Financial Reporting Package (FRP) for all financial institutions operating in the Philippines. Accurate, complete and timely FRP reports are crucial for the BSP’s supervisory role in maintaining the safety and soundness of the financial system of the country.
1. Inconsistent, inaccurate reporting
This entails wrong data sources, inaccurate computations, skipping data points and submitting reports with errors caused by over-reliance on manual processes, makeshift Excel collaterals, laying data using ad hoc structures and submitting reports without validations, cross-verifications, and authorizations.
A regulatory reporting framework can help by
- Using industry standard, evaluated and validated data structures
- Providing automated data flows
- Ensuring cross-validation and verification of reports with maker-checker workflows
2. Lack of documentation
Banks manage regulatory reporting with processes and data sources that have evolved with changing regulatory requirements. The continuous change with time, coupled with multi-team ownership of the data infrastructures results in inadequate and incomplete documentation, which makes it very difficult to introduce changes to the environment. This leads to inheriting definitions without clearly understanding them and lack of transparency on computation logics thus making it tremendously challenging to keep up with regulatory changes.
A regulatory reporting framework can help by
- Providing clearly identified data sources
- Providing detailed computation, data flows, and workflows so that documentation can be generated from the framework rather than preparing documentation without a clear connect to the framework.
- Making every computation, aggregation, value code mapping, and data quality addressal clearly auditable, editable, readable, and easy to generate as and when required.
3. Incorrect mapping of data
It is essential to understand the coverage of the regulations for each computation and prepare the correct mapping of data sources to regulatory reports with the relevant metadata. The amount and accuracy of required mapping is very high in regulatory reporting. While at the outset, the mappings are performed as a part of the coding processes, they eventually get moved to parameter files and ad hoc tables to help with maintainability over a period of time. The use of these traditional systems leads to myriad access issues, maintainability issues and ownership issues resulting in failed inaccurate mapping.
Incorrect mapping can lead to disagreeable consequences like completely leaving out portfolios while reporting, inaccurate figures, misrepresenting the bank’s financial position.
A regulatory reporting framework can help by
- Providing a simple UI for maintaining mapping information
- Ability to change mappings with role-based security and approval workflows
- Showing mappings in a simple, readable form to bankers for validation
- Ability to prepare documentation with such mapping information
4. Lack of transparency
Transparency has become increasingly important when it comes to regulatory reporting. Banks can no longer refer regulators to complicated applications without building their own comprehensive understanding of the reports. The nature and sophistication of the current regulatory environment demands that all computation, mapping, and aggregation of data needs to be transparent, traceable, and available for edits and reviews.
Lack of transparency can beget detailed inquiries from regulators, along with lowered trust in the reporting integrity. In the event of errors, tracing and rectifying them can pose a significant challenge.
A regulatory reporting framework can help by
- Providing auditable data aggregations and data flow
- Providing editable and reviewable computation logic and code for every computation, aggregation, or mapping
- Ensuring auditability of the entire data flow and report preparation by the regulator without any assistance from the bank
5. Insufficient validations
For regulatory reports, data is procured from multiple sources within the bank. Prior to submission, multiple data validations and report cross-validations are essential to rule out discrepancies. These validations ensure rigor and accuracy in compiling reports with detailed, structured data upholding them.
Reports not tallying opens up lengthy reconciliation issues while exposing the bank to additional regulatory audits fines, and actions.
A regulatory reporting framework can help by
- Ensuring data validation by design
- Ensuring cross validation of reports as mandated by the regulator
- Providing configurability of additional checks to cater to specific requirements
6. Inaccurate interpretation of the regulation
Regulatory requirements are complex in nature due to their continuous evolution over time in response to market events. Often, the translation of regulatory understanding to codes and reports is riddled with knowledge gaps. Inaccurate interpretation of regulations can result in reporting of inaccurate data points leading to errors in regulatory reports. Regulatory reporting cannot be treated as a bank’s usual reporting projects like MIS or BI reports. It requires robust functional and domain expertise for keeping pace with constant changes and delivering consistent efficacy.
A regulatory reporting framework can help by
- Providing prebuilt content put together by highly experienced bankers with in-depth knowledge of regulatory reporting
- Ensuring the prebuilt reports are validated across multiple implementations.
- Providing ability to check computations, aggregations, data flows in the framework in accordance with the regulations.
7. Inefficient data infrastructure
Data infrastructure is a key enabler in meeting the ever-changing demands of regulatory reporting. A strategically designed data infrastructure goes beyond the narrow focus on current reporting requirements; it factors in the entire regulatory landscape of the bank.
For many banks, data infrastructures are suboptimal with a narrow focus on producing regulatory outputs without consideration for data completeness, multi regulation support, and usability for basic MIS and BI reporting. They are also not built for agility to handle constant changes due to regulatory updates. Reuse of legacy infrastructures is also an issue since these infrastructures are subject to business definitions that may vary from regulatory definitions.
The usage of dated infrastructures leads to a constant struggle with assembling data for reporting. For every regulatory change, the entire data infrastructure undergoes change, resulting in long turn-around times and missing deadlines, data redundancies and inefficient data infrastructures. This adversely impacts the regulatory reporting process, making it cumbersome, error-prone and difficult to maintain.
A regulatory reporting framework can help by
- Providing industry-standard data model addressing all facets of banking
- Making provision to hold data relating to multiple regulations
- Providing separate infrastructure for regulatory reporting with well-defined data infrastructure
- Ensuring data structures are tested across multiple projects for coverage and efficiency
8. Adhoc changes in response to regulatory changes
Regulatory reporting is dynamic by its very nature, constantly changing in response to market events – local as well as global. A tech solution for reporting has to be crafted to anticipate every change by the regulator and respond to it with swiftness and ease.
Many banks react to regulatory changes with ad-hoc changes in the system. These are initiated by multiple team members without coordination, changing shared tables, introducing new definitions and lacking proper documentation, leading to an uncontrolled, undocumented and overly complicated data infrastructure. Responding to regulatory changes as a knee-jerk reaction can also lead to breaches of multiple principles set forth by regulators related to data handling, including BCBS239.
A regulatory reporting framework can help by
- Embracing change by design
- Making provision for incorporating regulatory changes with minimal changes in UI and no-code environments with IDE
- Providing the ability to break down regulatory change into smaller logical components that can be incorporated into the infrastructure
9. Unauthorised Report Submissions
Regulatory reports are a representation of the bank and must be authorised by respective business owners and designated officers before submission.
Reports without a clearly defined hierarchy of internal controls, validation and approvals can lead to duplicate report submissions, overwriting reports already submitted with authorization, submission of empty reports or reports with errors. This can tend to happen when there are separate data and digital applications such that reports are prepared with data applications and set for approval using digital applications. A unified platform that brings together both the functions is required to streamline regulatory reporting.
A regulatory reporting framework can help by
- Bringing data and digital on the same platform
- Enabling workflow engines to push reports through approval workflows
- Offering customisation to incorporate organisational and additional operational needs
10. Uncontrolled manual adjustments
Manual adjustments are an inevitable reality in regulatory reporting arising for multiple practical reasons, such as back-dated entries that are not present in the data, errors in the source system that are pending rectification etc.
Even though manual adjustment is an important functionality, it needs to be tightly controlled for efficacy. Uncontrolled modification of reports may only introduce more errors and inefficiencies if they modify reports beyond requirement. It is important that manual adjustments are provided for only at the data level, and no editing of data is allowed at the report level.
A regulatory reporting framework can help by
- Providing for manual adjustments to be controlled with role-based security
- Providing for manual adjustments to be put through the workflow for approvals
- Permitting adjustments only at the data level
- Making provisions for introducing adjustments with expiry dates to avoid such adjustments in time periods where they were not required
11. Missed deadlines for submission
Regulatory reports are driven by timelines. Missed timelines result in regulatory fines and reputational damage for banks.
Without a streamlined system with all its validations and checkpoints, regulatory reporting is very time-consuming with exhaustive manual processes and data jumping between systems and workflows before it is finalised.
A regulatory reporting framework can help by
- Ensuring fully automated report preparation and submission
- Enabling report schedules with reminders for starting the process and following through to submission
- Providing for auto-escalation of missed deadlines before a timeline breach
12. Missing audit trails
Since regulatory reports reflect the financial position and operational outlook of the bank, it is imperative that they have strict security and detailed audit trails. Audit trails can be easily logged and reproduced if the records are maintained in the same system from data sourcing to submission to regulators.
When banks operate regulatory reporting on multiple systems and applications, they are open to exploitation since audit trails are not comprehensively available in such setups. Absence of audit trails leads to significant loss of trust in the reports since the regulator will not be aware of the modifications made, and the source of these modifications.
A regulatory reporting framework can help by
- Providing end-to-end coverage of regulatory reporting in a single system
- Providing extensive audit trails for every aspect
- Providing readable audit trails
Conclusion
Accurate, complete and timely FRP reporting is crucial in ensuring compliance with BSP’s regulatory requirements. It is a representation of the financial institution’s health, integrity, and strategic outlook. But it doesn’t have to be a cumbersome and challenging process – by taking care of the aforementioned 12 areas, regulatory reporting can be made easy and smooth.
As financial reporting requirements continue to evolve, it’s important to stay updated with the latest guidelines and regulations. Atumverse, a comprehensive and integrated regulatory reporting platform offers a range of benefits to help financial institutions comply with regulatory requirements, including BSP regulatory reporting. By partnering with Atumverse, you can streamline your reporting process, reduce errors, and save time (start generating reports in 3 weeks!) and resources.
You can also schedule a consultation with our experts to learn more about Atumverse’s BSP regulatory reporting platform and take the first step towards ensuring accurate and timely reporting for your financial institution.