An overreliance on manual workarounds and tactical mitigants are preventing G-SIBs from realising the full benefits of BCBS239. Alan states that in order to address this challenge firms are “Implementing large-scale projects to improve their IT architecture and infrastructures, but many are also relying heavily on manual workarounds and tactical mitigants in their efforts to achieve compliance.”
Alan also believes that “Manual workarounds and tactical mitigants are typically major constraints on the flexibility, adaptability and operational robustness of BCBS239 solutions. They may achieve compliance on a superficial ‘box ticking’ level, but they do not go to the heart of addressing many of the deep seated challenges surrounding risk data aggregation and reporting that BCBS239 was introduced to address.”
Though with many elements of their programme still unclear, Alan still emphasises the scale of the task ahead. “Few people deny that tackling BCBS239 is a daunting challenge for firms, but many must be mindful of the consequences of relying too heavily on manual workarounds and tactical mitigants. They can bring short-term gains, but they also compromise the long-term value and benefits”.