Engagement Summary
In mid-2021, Monticello Consulting Group (Monticello) partnered with the Global Markets Transformation team at a leading financial institution to support the delivery reset and replanning of a large-scale regulatory program. This reset was initiated by the client in response to an internal review that found the original delivery timeline at risk of missing the key regulatory implementation dates and minimal internal processes around change management and issue remediation. Monticello’s Financial Services Advisory and Change Management Practice Areas were brought in to help lead the program and provide additional support in preparation for an upcoming Office of the Comptroller of the Currency (OCC) regulatory audit focusing on these key areas.
Monticello deployed resources across numerous program work streams to support the Transformation Program Management Office (PMO) to track project plans, key milestones, risks, issues, and dependencies. The Monticello team combined their proven program governance toolkit and effective stakeholder communication to ensure key program risks and issues were successfully mitigated and resolved through sound governance. Additionally, Monticello managed all program reporting obligations and supported senior leadership and program sponsors through bi-weekly program status updates to the program’s working groups and Steering Committee to present progress made against the firm’s regulatory commitments.
Monticello’s Approach:
Case Study Detail
PROJECT BACKGROUND
The Global Markets Transformation executive team initiated a program reset on the key FRTB regulatory initiative that required a dedicated team of resources to assist with a cross-domain, business, and technology replanning effort to ensure successful delivery and completion by the required regulatory dates. Additional emphasis to improve change management and issue remediation practices in preparation for an external OCC examination was also required.
ENGAGEMENT OBJECTIVES
Program Management & Governance
Managed program governance under the change management function for the Global Markets business. Monticello supported the FRTB Program Management Office to drive the replanning effort and delivery of the regulatory program through stringent execution of project plans, timely risk, and issue management, and robust governance standards. The PMO function included the following Monticello team responsibilities:
Drove FRTB program re-planning efforts and built go-to-green plans for cross-program and workstream-specific deliverables and dependencies.
Integrated with existing governance routines and recommended the creation of new forums to ensure executive-level visibility of critical deliverables and effective monitoring of cross-program dependencies.
Coordinated workstream-level planning and agreement on FRTB scope, the timeline for delivery, RACI matrix, and key RAID items.
Created and managed a central repository to track all FRTB requirements. Created requirements governance standards and ran gap analysis process to identify missing requirements or insufficient level of required detail.
Ensured adherence to enterprise-wide program management standards.
Stakeholder Communication & Reporting
Leveraged a strategic communication structure to provide tailored updates to stakeholders at varying levels of seniority and accountability for program deliverables.
Chaired program-wide meetings to liaise with workstream PMOs on project statuses.
Led individual workstreams and project working groups from identifying requirements through production release and signoff.
Defined reporting routines and effective program governance processes to satisfy requirements and align with business needs. Critical program information was communicated through a dashboard that highlighted program status, path to green plans, and key risks, issues, and dependencies.
Formalized agile framework methodology and introduced new reporting metrics based on utilization of new fields for reporting purposes.
Change Management
Reviewed current project documentation and provided recommendations for enhancements; especially around test strategy documentation.
Initiated the creation of a Data Dictionary for the FRTB Program to be presented as part of the OCC Review.
Issue Management
Raised and tracked JIRA tickets for Front Office Technology teams to investigate and resolve gaps around identified differences between sensitivities generated for Basel 2.5 requirements vs. FRTB.
Data Management
Advised client on the best path forward given current state infrastructure & hardware challenges to support all data requirements needed for full-reval HVaR and FRTB.
Facilitated meetings between Front Office Technology, Risk Technology, and the Business to understand reference data systems and identify trade flows with capital charge spikes requiring remediation.
Developed roadmap for building formal FRTB data governance across the organization including defining critical data elements, along with mapping existing and new architecture and data flows.
Identified existing and new reconciliations and controls.
FRTB Standardized Approach (SA)
Maintained and adjusted where needed the global plan for EMEA CCR2 to respond to UK and US regulations.
Incorporated regulatory interpretations and documented business requirements for the design, build, and release of risk technology to collect Front Office trade data, calculate risk sensitivities, enrich data, and where required calculate capital charges.
BUSINESS VALUE
Monticello Consulting Group provides services across the financial services industry to establish compliance and reduce regulatory risks. By leveraging our program governance toolkit and strong stakeholder communication, Monticello enables clients to successfully navigate complex regulatory directives and turn challenges into opportunities to build effective business solutions. Our team partners with cross-organizational client teams and oversees the end-to-end execution for Consent Order remediation. With deep regulatory knowledge, change management expertise, and proven governance standards, Monticello successfully ensures global financial institutions can maintain a competitive advantage over industry peers while exhibiting sound market conduct and compliance within the regulatory landscape
