BCBS 239 - Tempting Example or Cautionary Tale for Non-Banks?

The Bank of International Settlement introduced the regulation proposal BCBS 239 for improved risk data aggregation capabilities for banks. It comprises 11 principles how risk data aggregation and reporting shall be organised and technically set up. The financial crisis has shown that banks had huge difficulties to report their risk positions accurately and timely to the regulators. For a rather long period of time during the peak of the crisis it remained unclear how much the banking system suffered from specific systemic risks. Since the publication 2013 banks are working to comply with BCBS 239. A progress report has shown that no significant bank in Europe was fully compliant by mid 2020 while most institutes had reported good progress on most of the goals apart from data architecture and IT infrastructure. However the new capabilites for the banks looked so tempting that the vast majority extended the scope of their BCBS 239 projects to benefit also in other fields of the 11 principles defined by BCBS 239. So what is so tempting by BCBS 239 and what hampers banks from reaching compliance? In this talk I will give a brief overlook of how banks appoached the transformation. It will be shown how non-banks can profit from spirit of principles while avoiding the pitfalls. Further I will talk about architecture used for banks and which tooling concepts works best for non-banks.