Case study

Reviewing and redeveloping Non-Performing Exposure and Forbearance

Future-proofing policies and processes

We successfully remediated the DNB findings, enforced clear data ownership and data quality monitoring. We delivered improvements in the process of default and loss registration, tracking of NPE, classification of forborne exposures across the entirety of the bank. We provided critical input for the remodelling of corporate PD/LGD models. We also ensured operational impact was minimised and made way for other bank-wide policies in terms of alignment on definitions, procedures, reporting data, and governing bodies.

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Project overview

CubeMatch was hired by a Dutch Banking client to provide Business Analysis to aid the review, redevelopment, and implementation of the process for recording and reporting of the new definition of default, Forbearance and Non-Performing Exposure because of Internal Models Investigation by De Nederlandsche Bank (DNB).

Challenges

  • DNB findings remediation.
  • Enforcing clear data ownership and data quality monitoring.
  • Revision and creation of processes and policies.
  • Ensuring full regulatory compliance.

Outcomes

  • Improvements in the process of default and loss registration, tracking of NPE, classification of forborne exposures across the entirety of the bank.
  • Minimisation of operational impact.
  • Critical input for remodelling of corporate PD/LGD models.
  • Making way for other bank-wide policies in terms of alignment on definitions, procedures, reporting data, and governing bodies.

Challenges

  • DNB findings remediation.
  • Enforcing clear data ownership and data quality monitoring.
  • Revision and creation of processes and policies.
  • Ensuring full regulatory compliance.

Outcomes

  • Improvements in the process of default and loss registration, tracking of NPE, classification of forborne exposures across the entirety of the bank.
  • Minimisation of operational impact.
  • Critical input for remodelling of corporate PD/LGD models.
  • Making way for other bank-wide policies in terms of alignment on definitions, procedures, reporting data, and governing bodies.

// Objectives

Our client, a major Dutch Banking client, approached us as they primarily needed help to remediate the DNB findings, enforce clear data ownership and monitor data quality. They also needed help to improve their processes to future-proof them in line with governance, data, and methodology practice guidelines.

// Solutions

Our team of experts conducted a gap analysis to identify to-be policy, processes, and procedures due to the new definition of default. They established new unlikeliness-to-pay and days-past-due frameworks for application to client’s systems and default process.

Additionally, our consultants created an “Implementation Plan” to document key stages in implementation and decommissioning of impacted tools. A business impact analysis was conducted on disputed outstanding invoices, to determine the non-material impact of the out-of-scope system data. A memorandum was created to demonstrate impacts to the regulator and an investigation into data interfacing for reporting (FinRep/AnaCredit) was also performed.

// Outcomes

We successfully delivered the remediation of the DNB findings, while enforcing clear data ownership and data quality monitoring. We improved the process of default and loss registration, tracking of NPE, classification of forborne exposures across the entirety of the bank. We provided critical input for the remodelling of corporate PD/LGD models and ensured operational impact was minimised. This project also allowed our client to make way for other bank-wide policies in terms of alignment on definitions, procedures, reporting data, and governing bodies.

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