BCBS 239 Independent Review

An answer to the regulatory obligation…

The BCBS 239 text, as part of principle 1, requires Banks to validate with high standards their compliance to the overall BCBS 239 requirements. Moreover, the last publications by regulators reaffirm the higher supervisory expectations to reach the compliance and hence on the validation of the compliance. Indeed, the supervisory assessment conducted in banks has showed some gaps between supervisors’ assessment and the own assessment performed by banks.

Our view is that, in order to reach the highest standards, an external review by a team with i) a deep knowledge on this regulation, ii) a strong / multiple experiences of the place practices as regards this latter and iii) fully independent to the institution is the best answer.

…personalized to each Bank’s specificities and its BCBS 239 approach…

Deloitte’s approach relies on its analysis and experiences of the BCBS 239 requirements, materialized through a dedicated assessment tool, as well as a deep customization based on:

• Institution’s specificities, which could be related to specific business(es), organization, size (e.g. G-SIB, D-SIB)… 
• The BCBS 239 approach / answer undertaken, most of the time through a specific program / project, by each banks.

…taking into consideration the dynamic aspect of compliance to the principles.

As banks are always in perpetual mutation and evolution, the compliance in time need to be ensured and adapted to them. They are mainly link to i) strategic decisions such as merge and acquisition, restructuration, launch of new activities… and ii) “Business as Usual” evolutions / strategic projects related to, for examples, IT overhaul, new regulatory requirements/reports, internal monitoring of risk (e.g. new metrics)…

Moreover, this dynamic aspect should also reflect the supervisory expectations that are constantly increasing as remained in the last publications.