BCBS 239 at Commerzbank: Applying a Central Standards/De-central Implementation Approach

Joachim Pfeifer and Natalia Kluger

“Where is the wisdom we have lost in knowledge? Where is the knowledge we have lost in information?” T.S. Eliot

Commerzbank is one of Germany’s leading banks for private and corporate clients, and an internationally active universal bank with locations in almost 50 countries. It has one of the densest branch networks of any private sector bank in Germany. In total, Commerzbank serves more than 18 million private and small business customers, and more than 60,000 corporate clients worldwide. It uses a comprehensive system of ratios and procedures for measuring, managing and limiting various types of risk. To ensure a consistent and sustainable implementation of compliance with the 11 relevant principles of BCBS 239, Commerzbank chose an implementation approach that took into account the bank-specific circumstances, focusing a central translation of the BCBS 239 principles into bank-specific standards that guided a de-central implementation. This decision shaped the way Commerzbank perceived relevant topics of BCBS 239, such as materiality and particularly data management with data quality, as well as how compliance was to be validated on an ongoing basis.

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