Engagement Summary
Monticello Consulting Group (Monticello) recently partnered with a leading financial institution to support the delivery of a large-scale data remediation and controls program. The goal of the program was to 1) transform the list of external trading venues into a digital platform 2) build detective controls to discover broker and electronic activities being placed on an external trading venue that is not recorded on the inventory list, and 3) develop an escalation management process for the exceptions. These deliverables enhanced the client’s transaction monitoring and trade surveillance capabilities while ensuring regulatory compliance.
The Monticello team combined their proven project management toolkit and effective stakeholder communication to ensure key program risks and dependencies were successfully mitigated and delivered. By leveraging strong data analytics skills and capital markets knowledge, Monticello was able to quickly identify data quality issues and provide sound data remediation plans to eliminate the gaps identified across dozens of source systems and multiple asset classes globally. By applying an Agile methodology and working closely with the client’s SMEs from various functional groups, Monticello successfully implemented the solutions on time, on budget, and with the highest quality.
Figure 1 – Project Workflow
Case Study Detail
PROJECT BACKGROUND
Monticello’s client was looking to implement a digital platform for their trading venues inventory and establish appropriate controls within the year. Given the immense amount of data across various asset classes, systems, geographies and jurisdictions, numerous critical dependencies were required to be completed within a tight timeframe before the controls could begin to be built out:
Assess accuracy and completeness of critical data elements in the trading source databases and remediate data gaps.
Verify and document pre and post-trade data flow via multiple channels: portal, electronic, and voice/chat.
Create mapping tables to accommodate various internal and external product taxonomies used by the institution.
Build a relational data model to demonstrate data hierarchy in the new system.
Provide evidence of data alignment and demonstrate the concept of controls between the trading venues inventory system and trade repository system.
Upon delivering the key dependencies, the technology solution for the trading venues inventory system and detective controls needed to be completed in eight weeks, thus proving the effectiveness of the controls.
ENGAGEMENT OBJECTIVES
Program Management
Implemented a project management structure to facilitate effective communications across key project teams, manage project scope and track project progress.
Communicated project goals and objectives with key global stakeholders across sales & trading, the first line of defense, the second line of defense, technology, and operations.
Tracked project risks, issues, and dependencies and held weekly project working sessions to ensure stakeholder engagement and early escalations.
Developed KPIs and reporting metrics for executive management communications.
Data Management & Analytics
Collaborated with the development team to deliver system solutions of the trading venues inventory and build automated control processes to detect any circumvented activities.
Identified the key data points to locate global markets trading activities such as trading venues, Volcker desks, and traded products from dozens of source systems.
Designed and tested data queries in coordination with technology and operations teams to facilitate complex trading flows across multiple asset classes: equities, rates, spreads, commodities, and financing.
Conducted a 5-week “proof of concept” exercise before development started to demonstrate the logic and the effectiveness of the detective controls by using data analytics tools such as SQL, Tableau, and Python.
Supported User Acceptance Testing by creating test plans, remediating data quality issues, and creating matrices for SLA verification.
Created a centralized SharePoint to manage documents and store data records to suffice audit requirements.
Agile
Improved the delivery capability of the technology team by following an Agile methodology through multiple iterations.
Managed the progress of the code delivery and incorporated end users’ feedback to the working code on a daily basis.
Tracked data quality issues through Jira to ensure the transparency of data remediation progress.
Organized daily stand-up meetings to address development issues and highlight delivery priorities.
Created burn down charts to present weekly development progress to key stakeholders.
BUSINESS VALUE
Monticello Consulting Group provides services across the financial services industry to establish compliance and reduce regulatory risks. By applying expertise in project management, data analytics, Agile methodologies and strong stakeholder communication, the Monticello team successfully implemented a sustainable solution for this large-scale global data controls project to successfully enhance its client’s trade monitoring and surveillance processes. By working collaboratively across sales & trading, first line of defense, second line of defense, technology, operations and audit, Monticello aligned all stakeholders to ensure the timely delivery – ultimately allowing the client to maintain competitive advantage over industry peers while exhibiting sound market conduct and compliance practices.
