The Fourth Day of BCBS 239: Completeness

By Stephen Engdahl | 9 December 2014

Gifts for the good girls and boys: Check.

Sleigh with sufficient cargo space: Check.

Santa suit for authenticity: Check.

But this operation won’t get off the ground unless G. Sibley can produce Rudolf, right?

Risk analysis doesn’t work if a core piece of information is missing. So when considering data definitions, data governance, and data architecture, it’s important to ensure a program is in place for all relevant attributes.

Risk data falls into several broad categories.

It requires information about corporate entities and their associated hierarchies and relationships, including your relationship to them. This is data such as Customer, Counterparty, and Issuer details. This category should also include data about your own firm, your own subsidiaries, departments, and even employees.

It requires information about Securities of all asset classes, and the information related to them including terms and conditions, corporate actions, prices, classifications, and more.

It requires your firm’s transactions and positions, along with those of your customers across all of their various accounts.

You might be managing some of these appropriately today relative to your target BCBS 239 framework. But failing to address all of these is akin to doing nothing at all to address your data management processes, and being left with a grounded sled on Christmas Eve.

  • BCBS 239 Principle 1 makes reference to entities, customers, counterparties and accounts.
  • BCBS 239 Principle 8 makes reference to exposure and position information.

Even with a scope this large, GoldenSource has learned that an iterative approach to data management implementations is the best path to success. Each discrete project must be structured to provide immediate ROI, while still building toward an integrated framework offering high data integrity across data sets and low ongoing cost of operation. Whether you’re looking for a platform to handle all of your critical data on a single infrastructure, or have a specific project in mind to shore up one area of weakness, it is important to choose a platform whose span of coverage includes each of the major data sets described in BCBS 239.                                                                                                                

Now that we’ve finished Day 4, the fundamentals are in place – data definitions, governance, architecture, and scope. Join us tomorrow for G. Sibley to begin an exploration of the capabilities he will need to establish on top of these fundamentals.      

Look out for day five tomorrow.


By Steve Engdahl, SVP, Product Strategy, Goldensource 

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