Introduction

Peter Haines

A quick Google search for BCBS 239 provides us with some (abbreviated) first page results:

    • “The only three things you need to know about BCBS 239”;
    • “What does it cover and how can banks comply?”;
    • “BCBS 239 thematic review: A challenging test”; and
    • “Living with BCBS 239”.

Those familiar with the subject will probably be accustomed to these sorts of opinion pieces. However, for those new to the regulation, you are hopefully starting to get a picture of some of the difficulties involved. The inability to reliably aggregate data, specifically credit exposures, at the time of the 2007–08 crisis was the instigator for regulators to force banks to fix the plethora of issues with their data estates.

What is interesting is that a number of these articles have a published date on Google later than the January 1, 2016, regulatory compliance deadline – one that, for all intents and purposes, was missed by most (if not all) of the industry. It is important to note at this point that the regulatory text was published in 2013, so was this a question of complexity of responding to the requirements or more about the level of industry preparedness? Since the d

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