Engagement Summary
As a result of an internal audit, our client’s equities and fixed income technology groups recognized that their applications that send trade data to surveillance systems lacked data completeness, defined SLAs, and sufficient monitoring and escalation protocols. As a result, first and second line of defense trade alerts were at risk of delay and not aligned with internal policies or external regulations. Monticello’s Financial Services Advisory and Change Management practice areas were brought in to lead the program and eliminate the gaps that existed in the legacy controls to ensure compliance.
The Monticello team performed an assessment of the current state and developed a strategic roadmap that aligned people, process, and technology. The team provided project governance and implementation support that allowed the client to meet regulatory and internal deadlines for the complex global stakeholder initiative. A key factor in the project’s success was the team’s prior experience collaborating with project partners across multiple geographies and their experience with the complex system landscape. By leveraging their capital markets, trade surveillance, and technological domain knowledge, Monticello was able to quickly assess the situation and make recommendations based on industry accepted best practices. In conjunction with the client’s SMEs, Monticello was also able to define and implement solutions on time, on budget, and in a manner that considered the future state landscape – ensuring that the solution was able to handle new systems and products as they are rolled out in the years to come.
Case Study Detail
PROJECT BACKGROUND
In today’s data driven world, financial institutions are monitoring trading activities on more markets than ever before, which in turn requires enhanced visibility across multiple trading venues, sources, and asset classes as the pool of data grows exponentially. Along with this growth comes greater scrutiny from regulatory authorities who apply systematic controls and surveillance procedures to ensure compliance.
As a result of an internal audit, our client identified an issue centered around data completeness within their surveillance data repository during periods of enhanced trade volume which was initially uncovered during the Covid-19 pandemic induced trading craze. Given the vast number of systems, geographies, and jurisdictions involved, it was determined that a current state assessment was required. This would include a review of the fixed income, currencies, commodities and equities applications that send trade data to internal supervision and surveillance systems to clearly map the existing controls, review for adequacy, identify areas of weakness, and define enhancements and solutions. Once implemented, the bank could ensure confidence that their surveillance monitoring models are complete, accurate, and future-proof.
ENGAGEMENT OBJECTIVES
Program Management
Actively engaged stakeholders from 50+ teams and implemented a scope management plan and associated work breakdown structure for applications within the realm of the asset classes outlined for this program.
Managed and communicated overall project goals and objectives with the technology owners of the 50+ applications in scope. Collaborated on the timelines, benefits, and format of the program rollout to ensure stakeholder engagement.
Developed KPIs and reporting metrics for executive management communications.
Addressed and escalated risks at the earliest possible point while attaining necessary sign-offs required for completion of audit remediation.
Data Management & Analytics
Designed application analysis templates to capture the current state of the client’s system architecture.
Documented data flows utilizing Visio to illustrate the data journey from source/origination, enrichment, and through to the surveillance applications along with each associated hand off point along the way.
Created matrices to easily provide visual summaries of gaps identified and trends across the system landscape.
Created a centralized SharePoint to manage the document store, reporting process, and to provide automated program and workstream level RAG status.
BUSINESS VALUE
Monticello Consulting Group is a trusted partner serving the financial services industry with a consistent track record of helping clients reduce their regulatory risks while improving operational efficiencies. By working with our client to successfully translate complex regulatory requirements into effective business solutions, the Monticello team implemented the risk management and technical controls to ensure trading and system of record applications were robust. The Monticello team partnered with the owners of approximately 50 applications across 5 business areas to identify issues for remediation. Monticello utilized our proven Agile project management and project governance approach that allowed the client to roll out solutions faster and with quality resulting in significant time and cost savings.
