The modernisation of EFS reporting ecosystem has been driven by APRA’s efforts to improve relevance of data collected and to improve the quality of data to be reported, including seeking additional and granular data requirements, updating existing data definitions to match evolving national and international standards, and imposing data quality and audit mandates.
EFS reforms have the potential to touch across all aspects of reporting entities reporting value chain and reporting infrastructure. Existing archaic regulatory reporting processes and technologies will prove to be highly misaligned with new reporting requirements resulting in not only non-compliance glitches but significant add on costs. With the compliance clock ticking loud, entities will have to be pro active in realising and acting on the tremors poised to emerge from EFS modernisation. The implementation timeline is challenging to all financial institutions and given the relative scale of change, by now, entities should have acted and should be acting on a number of issues as listed below, if they need to stay compliant with new EFS reporting regime.
- Entities should ensure thorough understanding of various nuances of EFS change, including a multidimensional and clear view of new reporting requirements and gaps from existing requirements
- Due to additional, relevant and granular data sought, entities must by now, have a robust data acquisition and data alignment strategy with the new reporting requirements.
- Given Introduction of new counterparty classifications, entities must ensure alignment and up to date definition of new classifications with their existing data points.
- Improving data quality laying at the heart of EFS reform, reporting entities must identify appropriate systems and processes to ensure data quality thresholds imposed. While at the same time, reporting entities must have a thorough understating of audit requirements, i.e., the alignment with APS 310 and thus identify and invest in agile systems that can fulfill data quality and audit needs
APRA EFS while in itself is a major reform imposed by APRA after nearly more than a decade, there is multiple regulatory reforms clouds looming over, be it, the liquidity reporting requirements facelift from early 2018, upcoming SA-CCR reform, large exposures overhaul, to name a few. There appears to be a common thread tying these reforms altogether, its APRA’s and global regulators effort to seek ever more granular, ever more relevant and ever more quality data in an effort to shift regulators role from being consumers of data to being partners making reporting entities to ensure they are future proof, or they perish.