Dodd-Frank Reporting: Live Positions Migration for Money Center Bank

As part of the Dodd-Frank Wall Street Reform legislation, our client was required to backload live position data to the DTCC's Global Trade Repository (GTR) across several asset classes. Monticello Consulting Group was retained to assemble a team to coordinate and execute the backload of all live positions from various front office systems into an internal rules validation system, and further into the industry-wide trade repository. The team developed a custom process to test, execute, and validate end-to-end results of this effort for two successive compliance dates:

  • Compliance Day 1 - Rates & Credit positions
  • Compliance Day 2 - FX & Equities positions


Client & Objectives:

  • A money center bank tasked with publishing live positions across multiple front office trading systems to the DTCC’s Global Trade Repository in line with regulatory timeframes
  • Aiming to accurately and efficiently manage the impending implementation


Challenges faced by Monticello:

  • Develop a new method to manage the end-to-end backloading process
  • Bring together disparate systems and technology teams across the globe
  • Manage large populations of data in an efficient manner
  • Optimize capacity management of under-staffed project teams


Actions taken by Monticello:

  • Streamlined mechanisms and workflows for straight-through-processing of data
  • Re-engineered multiple MS Access databases into a single SQL Server database to enhance position throughput and simplify data reconciliations
  • Improved quality control by incorporating static data reviews prior to test cycle execution
  • Led frequent team meetings to drive collaboration and gather clear requirements for superior execution


Results Achieved:

  • Reduced the overall processing time by 25% for position migrations between CD1 and CD2 milestones
  • Attained a 99% success rate on initial migration into the Global Trade Repository (GTR)