A big domestic bank implements the regulatory requirements according to SFTR (Security Financing Transaction Regulation) within a project. The creation of the supervisory conformity starting with the reporting obligation in July 2020 is a prerequisite for the continuation of the legal capacity in the money market. The breach of it can either cost a fine or lead to a restriction of the legal capacity (article 22, paragraph 4 SFTR).
The fundamental challenge was in the aggregation of all relevant information from different source systems in combination with the necessity of a timely survey, preparation and transmission of business data.
For the implementation of the regulatory requirements, at first, an impact analysis was carried out. As a second step, an extensive expansion of the existing data base for repo and securities loan businesses in trading systems and numerous interfaces was made. Thereby, it was guaranteed that the regulatory requirements are implemented appropriately and completely and embedded efficiently into the existing process and system landscape.
The selected project method with agile elements allowed early test activities, in order to integrate the partially very spontaneously announced changes of ESMA and BaFin appropriately into the implementation. Furthermore, the chance of pre-production was used to experience the SFTR reporting process close to the running system over a longer period of time. For the users a “plunge” during the regulatory go-live process could be avoided.
A key element during the successful project creation was that an interdisciplinary team took care of the tasks and responsibilities in the roles of the project managers, the specialist leads as well as the test management and test conduct. Therefore, an efficient and effective controlling of the internal as well as further external project participants was possible, in order to achieve the project goal successfully.
The SFTR implementation was carried out with maximal efficiency in the best interest of the customer, taking into consideration the operation, the maintainability and the controllability of the solution.
“Early testing activities and the use pre-production lead to a high reporting quality and avoided for the specialist department a plunge after the go-live"
Patricia Georgi, Managing Director, targens