Data engineering · Banking

Risk data aggregation and lineage (BCBS 239)

We build risk data aggregation and lineage for BCBS 239: an inventory of critical risk data, clear ownership, automated lineage from source to report, quality controls and reconciliations, and risk reporting that can be produced accurately, completely and quickly, including in a crisis. The aim is data that supervisors can test and that risk managers trust, and you own the platform and the code.
Drawing for Risk data aggregation and lineage (BCBS 239)
Requirements pack · Banking finance

Bank reporting and controlling requirements pack

A requirements pack for regulatory reporting, treasury and liquidity reporting, and management controlling systems in a bank: data, definitions, calculations, validation, lineage, close and governance.
  • 01Eight requirement areas shared by regulatory, treasury and controlling reporting.
  • 02What to ask for on data definitions, lineage and reconciliation.
  • 03Close, sign-off and change-management items auditors check.
  • 04Seven questions to put to any vendor or development partner.
Free download

Get it on screen in a few seconds.

No newsletter. We use your details to follow up once about the download, and you can ask us to delete them at any time.
What it covers

What the system does, module by module.

  • 01

    Critical data inventory

    Identification of the data elements that drive risk reports, with business definitions, owners, sources and the reports that use them.
  • 02

    Governance and ownership

    Named data owners and stewards, decision rights, policies and a forum to resolve conflicts, recorded in the system and not only in documents.
  • 03

    Automated lineage

    Lineage captured from pipelines and queries, from source field through transformations to risk report cell, with impact analysis for changes.
  • 04

    Data quality framework

    Rules for accuracy, completeness, timeliness, consistency and uniqueness on critical elements, with scores, trends, owners and escalation.
  • 05

    Reconciliation

    Automated reconciliation of risk data to the general ledger, source systems and prior reports, with breaks explained and tracked to closure.
  • 06

    Exposure aggregation

    Aggregation of exposures by counterparty, group, sector, country, product and other dimensions, with consistent hierarchies and identifiers.
  • 07

    Ad hoc and stress reporting

    The ability to produce new cuts and stress scenarios quickly from the same governed data, including requests under time pressure.
  • 08

    Risk reporting production

    Scheduled and on-demand risk reports with validation, review and sign-off, and a clear statement of the limits of the data.
  • 09

    Self-assessment and evidence

    Mapping of controls to the BCBS 239 principles, with gaps, action plans and evidence for the board and for supervisory reviews.
Architecture

Reference architecture.

Risk data aggregation and lineage: reference architectureSource systems for credit, market, liquidity and finance feed a risk data platform with a critical data inventory, governance, automated lineage, data quality, reconciliation and exposure aggregation. Risk reporting, ad hoc analysis and supervisory evidence are produced from the same governed data.Source systemsRisk data platformConsumersCredit and counterpartyExposures, ratingsMarket and liquidityPositions, cash flowsFinance and reference dataLedger, hierarchiesRisk data aggregation platformCritical data inventoryElements, ownersLineageSource to report cellQuality frameworkRules, scoresReconciliationTo ledger and sourcesExposure aggregationGroup, sector, countrySelf-assessmentPrinciples, evidenceGovernance records · impact analysis · audit trailRisk reportsBoard, committeesAd hoc and stress requestsFast new cutsRegulatory reportingReturnsSupervisors and auditEvidence
Reference architecture: one governed chain from source to risk report, with quality, lineage and reconciliation built into each step.
Standards and interfaces

What we design against.

BCBS 239
The Basel Committee's principles for effective risk data aggregation and risk reporting: governance, data architecture, accuracy, completeness, timeliness, adaptability and supervisory review.
Supervisory guidance on risk data
Guides and assessments by supervisors, such as the ECB's guide on risk data aggregation and risk reporting, which set out expectations in detail.
Data management frameworks
DAMA-DMBOK and ISO 8000 for data quality and governance practice.
Legal entity and instrument identifiers
LEI (ISO 17442) and instrument identifiers for consistent counterparty and product aggregation.
Open lineage standards
OpenLineage and metadata standards for capturing lineage from pipelines automatically.
Reporting and accounting standards
The regulatory returns and accounting bases to which risk data has to reconcile.
Data model

The core entities.

Critical data element
Name, definition, owner, steward, sources, reports using it and criticality.
Lineage graph
Source and target elements, transformations, run identifiers and versions.
Quality rule and result
Rule, dimension, threshold, outcome, trend and owner.
Reconciliation
Comparison, difference, explanation, approver and date.
Exposure
Counterparty, group, instrument, amount, currency, sector, country and the hierarchy used.
Report and cell
Report, cell definition, value, data cut-off and sign-off.
Principle assessment
BCBS 239 principle, controls, gaps, actions, owner and evidence.
Build, buy or extend

When custom development is the right call.

Buy

Data governance, lineage and risk data products cover the inventory, catalogue and lineage well, and are a reasonable foundation for banks with the budget and vendor relationships.

Extend

Extend a governance product with automated lineage from your own pipelines, reconciliation and quality controls that connect to the risk reports.

Build

Build when your data estate is heterogeneous, when lineage must be captured from your own pipelines, or when the aggregation and reporting logic is part of your own platform.
Security and compliance

Controls designed in, not added later.

  • Controlled access

    Risk data is classified, access is role-based, and sensitive counterparty data is masked for those who do not need it.
  • Change control

    Changes to definitions, rules and aggregation logic are approved, tested against history and dated.
  • Immutable reports

    Issued risk reports are stored with their inputs and can be reproduced exactly.
  • Lineage integrity

    A break in lineage or a failed quality rule on a critical element is flagged before the report is issued.
  • Resilience in a crisis

    Capacity and procedures for fast reporting under stress, tested regularly.
How we deliver

From discovery to a system you run.

  1. 01

    Gap assessment

    We assess current practice against the principles with risk, finance and data teams, and rank the gaps by supervisory attention and risk.
  2. 02

    Inventory and governance set-up

    Critical data elements are inventoried, owners named and the governance forum and tooling set up.
  3. 03

    Lineage and quality on the first reports

    Automated lineage, quality rules and reconciliations are built for the most important risk reports.
  4. 04

    Aggregation and ad hoc capability

    Exposure aggregation and fast ad hoc and stress reporting are added on the same governed data.
  5. 05

    Self-assessment and sustain

    Evidence is produced from the platform for self-assessment, and the process runs as business as usual.
Relevant work

Where to see our work.

Related

Keep reading.

Questions

Common questions.

Does BCBS 239 only apply to the largest banks?
It was written for global systemically important banks, and many supervisors apply it, or its principles, to domestic systemically important and other banks. Smaller banks use it as a benchmark for good practice.
What does automated lineage give us over documentation?
It stays accurate. Lineage captured from the pipelines is generated from what actually runs, so it changes when the pipelines change, and impact analysis tells you what a change will affect.
How fast can we produce a new risk cut?
As fast as the governed data allows. Once critical elements are modelled and reconciled, new aggregations and stress cuts are queries and not projects.
Does this replace our risk systems?
No. Risk engines remain. The platform makes the data that feeds them and the reports that follow consistent, traceable and reconciled.
Who owns the platform and code?
You do. The code, the rules and the data stay yours.
Next step

Tell us what you need built.

Describe the system and the systems around it. An engineer replies within 1–2 business days.Start a project