Initial situation

• The full-service universal bank’s data architecture and IT landscape are very complex because of its federated setup and origin in mergers of many smaller banks – making proper RDARR (Risk radar reduction) difficult

• In the RDARR MVP project 2018-2021 – in part supported by zeb – the full-service universal bank uplifted its RDARR capabilities – with a scope limited to 25 (mainly credit) KRIs of the group risk report

• ECB conducted an on-site inspection (OSI) on BCBS 239 at the full-service universal bank – 19 findings (one F4 “very high” finding) are to be remediated in 2023

• The CEO recently introduced a NFRPP (Non-financial Risk Reduction Plan) model to bring the full-service universal bank into a better NFR situation – being part of an NFRRP unlocks funding but also enforces a strict reporting governance

Approach

• OSI remediation program to reflect lessons learned from challenges in RDARR MVP, i.e., regarding

  • Centralized coordination and tracking

  • Silo-thinking in the full-service universal bank federated setup

• Nordea reverted to zeb as a partner – role zeb

  1. GDMO (1) support in initial scoping phase for the 19 findings

  2. PMO: tracking, reporting, coordination between stakeholders and ECB interactions

  3. Expert support and quality assurance of ECB deliverables

• The remediation program of the BCBS 239 OSI findings is a data risk reduction plan

  • Funding released by GLT (2) and centrally allocated and tracked by designated financial controller

  • 6-week reporting cycle to executive steering committee and CEO in GLT

(1) Group Data Management Office, (2) Group Leadership Team