Survey results 2013: Regulation and client servicing are driving the demand for better data management

May 23, 2013

According to the recent MoneyMate Data Management 2013 survey, regulation is the top driver of new data management projects for asset managers in 2013, with 68% of respondents flagging it as a key driver.

This was closely followed by client servicing, with 60% of respondents indicating that demand for better client service was driving demand for new data management initiatives.

Interestingly, driving efficiency was flagged by only 30% of respondents. This tallies with the view that strategic spend is outweighing tactical spend in 2013.

I was encouraged to see client service polling so high in this survey.  I believe it validates my long-held view that the reason we focus so heavily on applying good governance to client facing investment product data is because data is the oil in the distribution engine for many investment managers – feed the engine with poor quality oil (data) and within a short space of time that engine will seize up.

The indication that 68% of firms’ new initiatives are driven by regulation correlates tightly with what I hear on the ground – many firms are cognizant of the fact that transparency is something that is going to have to be embraced. Those that see this as a strategic opportunity are positioning themselves now for even greater demands for data in the to-be regulatory landscape that is developing in front of us.


Setting up a governance program for effective management of investment product master data – Part 10 – Move to Maturity

March 25, 2013

This is the last post in a series of blogs on setting up a governance program for the effective management of investment product data, in this blog I will wrap up the series with a discussion on how to move your governance program towards a mature model.

If you have followed the earlier 9 posts you will probably recognize many of the steps in the data governance evolution scale  I referred to in one of my previous blogs on maturity models for governance of investment product data (see image below).

Data Governance Evolution - from Chaotic to Predictive

The Data Governance Evolution Scale

As you embark on the instantiation of your program you will more than likely be working within a quite chaotic environment – one lacking in clear, top down driven policies and standards, and very much reactive.

As you start to take action and follow some of the steps that I have outlined in earlier posts you will start the journey towards maturity – initially you will need to go through the process of securing C-Level buy-in, and formulating terms of reference for the program, before embarking on the broader strategy definition.

Do not neglect the importance of the culture and organizational structure that will be needed to support and enable the governance program to succeed – in particular you have to think about the target operating model of stewardship that will be most effective for how your business is structured both now and into the future.

In order to move from the “chaotic” and “reactive” levels in the maturity model you must focus heavily on the following:

  • Ensure your strategy is clearly defined and communicated to all actors within the domain you are trying to apply governance too
  • Set out the policies and standards you want to promulgate, with clear alignment and reference to the strategic goals
  • Once you have the policies and standards down pat you will need to focus on ensuring you have a set of applicable processes and procedures that are aligned with the overall strategy – each process should be directly traceable back to a specific standard/policy
  • In parallel to the process of defining the policies, standards, processes and procedures (the how) you need to be working on building out your master data plan (the what)

If you have worked through the process above, you will have moved from a position of total vacuum, to a chaotic, to a reactive program of governance – in fact you have probably got further than many firms who claim to have governance will ever move past.

To move from “reactive” to “defined” you need to make sure that there is a clear understanding of the data within the terms of reference of the program – all participants have to use the same nomenclature when talking about data, as inappropriate usage, miscommunication and misunderstanding of what is being discussed is the most common root cause of data quality issues I see. To this end, the construction of  a data dictionary is a fundamental step in moving your program to state of ”defined”.

Other areas you will need to focus on before you can consider your program to have achieved the level of “defined” in our maturity model are as follows:

  • You need to start the process of measuring your program – don’t fall into the data quality denial trap – identify the key areas (KPI’s) where useful measurement can contribute to a balanced score card that reflects how well the program is being executed. Think about KPIs that can point to the quality of the data – focus on the standard facets of data quality – timeliness, consistency, completeness and accuracy
  • Examine the operating model you have in place for stewardship - to what extent can it be made more effective and efficient by driving the rights issues to the right experts – in my opinion the stewardship model needs to be n-tiered in line with the back to front alignment of traditionally asset management businesses
  • As you develop and hone the standards and policies, the underlying process and procedure will start to snow-ball and it will become increasingly difficult to achieve the oversight and accountability that all governance programs require to be successful – to that end you will need to consider how technology can help support and frame your program, but remember technology is not a panacea to the ills of data governance and quality
  • For every issue, exception and concern raised through the program start tracking the root cause – this really does require a good underlying collaboration tool

Moving from the level of “defined” and onto “pro-active” and “predicative” will seem at face value to be relatively easy, but is very rarely achieved, in my opinion this is generally culture related – some of the key elements in moving onwards and upwards is buying into the continuous improvement principle – if this is not a core value in your firm you will find it difficult to progress in any meaningful way

So what are the key elements moving your program to the highest levels of maturity?

  • You need complete (firm level) buy-in to the concept of continuous improvement – with the appropriate feedback loops designed into your processes to ensure this becomes a core tenet in your program’s modus operandi
  • You need a specific set of activity centred on reviewing the root cause of issues being surfaced, such that they are being feed into the continuous improvement cycles for the relevant processes
  • Your master data plan and data dictionary will be seen as living breathing entities, that are constantly being updated and reviewed in line with the changes in your BAU operating models – these artefacts must never become stale. I often find this is the easiest way to demonstrate to a firm that their program is still in the “defined” stages of maturity, when they might argue otherwise
  • Your program will be making correct and efficient use of technology to empower and enable the data quality management process, supporting the people (stewards) to apply the governance
  • Your data architecture will be coherent and well designed for your organization and how it does business – I find discussion on architecture and the correct use (or not) of MDM, warehouses, marts, hubs, silos etc can be fraught with generalisms and so I will avoid pontificating on what I consider good architecture

When you are able to demonstrate that your program is constantly being tuned and refined, that you have demonstrable audit-trails, and your people, processes and technology are working in harmony, you are well on the way to achieving a highly predictive and mature governance program.

Before signing off of this 10 blog series, remember to keep your eye on the ball – think about the green grass on the other side of the river – the reason we focus so heavily on applying good governance to client facing investment product data is because data is the oil in the sales engine! Feed it with bad data and the engine will start to seize up…..and a business without sales has no future!


Setting up a governance program for effective management of investment product master data – Part 9 – Technology Frameworks

March 12, 2013

This is the penultimate post in a series of blogs on setting up a governance program for the effective management of investment product data, in this blog I will explore the importance of technology frameworks.

Investment product data quality is determined by: Completeness, Consistency, Timeliness and Accuracy – but to solve data quality  you need to consider: People, Process and Technology!

People Process Technology

Implementing a formal program of data governance and effective stewardship requires investment in supporting frameworks that empower people to apply the process.  While technology is not the solution to data quality– it has a really important role, and that is to provide a structured framework that empowers the stewards (people!) to apply the process!

Remember technology and your IT department cannot and will not solve your data quality problems – it’s role is to support and frame the process such that the people can do their job effectively.

The aspects of data governance, and of the data quality management process, where technology plays a key role are as follows:

  • Automation of data quality checks, ideally with a business intelligent rules engine. There are many generic DQM/EDM solutions on the market – think about a best of breed for the niche you are in though – they will deliver a greater ROI. Ensure your business rules engine is capable of schedule management, workflow structures, validation, reconciliation, transformation and derivation – ideally choose one with a Domain Specific Language that allows custom rule engineering
  • Effectively measurement of the process and reporting meaningful and actionable information – be that in the form of traditional MIS, KPI’s, Balanced Scorecards or bespoke dashboards. Operational oversight, trend monitoring and feedback loops are key elements in driving  a process to maturity (see next post in the series)
  • Assignment and delegation of ownership and accountability
  • Exception management, alerting, reminding and escalating data quality problems
  • Data mining and reporting
  • Critical to all processes under the remit of the governance program is that they are repeatable, automated and systematic – with a clear audit trail that ties stewards, to data exceptions, to historical temporal views of the platform

Remember though, the key role that technology plays is in providing a framework that empowers the stewards to apply the governance strategy, while allowing the governance function to oversee the application of the strategy.

In the last post of this series I will look at how to drive your governance program from day-care to maturity….


Setting up a governance program for effective management of investment product master data – Part 8 – Data Dictionary

March 6, 2013

This is part 8 of a series of blogs on setting up a governance program for the effective management of investment product data - in this blog I will explain why building and maintaining a data dictionary is probably one of the most important factors in the success of your program.

Like many business buzzwords, data dictionary means different things to different people. The common thread is that the dictionary is an inventory of the data items being consumed or produced within a specific defined business unit or process.

Why do we create them? Again, there are many reasons – but the most prevalent one is to bring a common understanding to play within a specific environment such that everyone is speaking the same language when it comes to data. Data management projects live and die by the quality of their data dictionaries because even within small teams you can have wildly different nomenclatures in existence for what seems at face value very simple, easily understood data items.

Before I get onto what makes up a data dictionary I would like to clear up a couple of misnomers I often come across:

- A data dictionary is not a document. Documents are two-dimensional, while data dictionaries work across many planes. They are best represented in a relational database, or if needs must, a set of interrelated Excel worksheets.

- A data dictionary is not a project resource – yes, every data management project needs a dictionary, but as a resource it has a life outside of the project. You do not create a dictionary to serve the needs of a project only – the dictionary is also required within the business-as-usual activities that come into play post a project delivery i.e. it is a resource that requires and demands constant attention, updating and refinement.

So what is commonly found in a data dictionary? As I mentioned earlier it is a centralised inventory of information on data items/fields that describes in detail the data items semantics, how the data relates to other data, where the data is consumed, where it is processed and from where it is sourced. The dictionary should also describe the correct format and syntax for each field.

So for each entry in the dictionary I would expect to find the following

- A specific unique name for the item

- A clear definition of the data items meaning, including references to other common/aka names for the item

- A list of all “consumer” entities and processes that consume/use this data item

- A list of all the “suppliers” or source systems that produce this data and deliver to processes downstream

- Specific mention of any master rules for choosing correct source system for specific situations

- A list of all business rules applied to the data item as part of any data quality management process that touches the data

- Reference to stewards or stewardship teams that are responsible for the management of the data

- Reference to subject matter expert(s) who can deal with questions about the data item

- Detailed syntax specification for the data item – including type, structure, format and example values

- Good dictionaries allow users enter and update specific notes and references à la a wiki

If you have constructed your data dictionary using a database then you can easily provide very helpful alternate views of the dictionary for example:

- Show all data items consumed by process X

- Show all business rules

- Show the data items touched by Rule Y

- For data item Z show all sources

- For data item R show all consumers

- and so on…

More advanced dictionary implementation have an integrated audit trail with the live system that can instantly show as-of  transactional views i.e. the dictionary and the real-world systems it relates to are integrated.

So how does one build the dictionary? In MoneyMate we build them out using a SIPOC process in reverse [COPIS]

- So we start off identifying all of the consumers of information

- From here working out what outputs are consumed by each consumer#

- From here working out which processes deliver the outputs

- From here working out which inputs are used in each of the processes

- Before finally identifying the source/supplier systems producing the inputs

A critical element of the COPIS/SIPOC analysis is identifying where certain data items have multiple source systems – in these cases we need to carefully specify the master data rules that indicate which source is correct for the variety of situations that dictate different usage of the data.

Examples of this problem would be:

- You could have multiple back-office providers which means your daily NAV could be flowing from multiple parties/systems

- You could also have different legal structures in play that have different statements of record for different data types e.g. for holdings you maybe using the accounting book of record for your mutual funds but for managed accounts you are taking data from your investment records.

- You could have standard source of performance for all in-house funds, but for sub-advised you take data from the sub-advisor

Clearly the dictionary needs to capture all of this information in a well structured manner and allow for specific notation of the master rules for each item which has more than one source.

So hopefully you have a better understanding of what a data dictionary is, what it contains and why it is needed.  If you have anything to add yourself – send me a PM or comment below.

Next up in the series is a review of the role technology should play….


Setting up a governance program for effective management of investment product master data – Part 3 – Defining the Strategy

January 31, 2013

If you have been following the previous parts of this 10 part blog on a blueprint for rolling out a data governance program for investment product data, you will be aware that I have covered aspects such as Organization and Terms of Reference  – to this point just about everything I’ve talked about could apply to any data governance program – now I am talk more about what is specific to the investment product master domain.

Based on the terms of reference for your program, you will have briefly analyzed the drivers within your firm that led to the decision  to apply governance to your client-facing investment product data - and ideally, you will have worked with your stakeholders to construct a simple vision statement that outlines what the program is setting out to achieve.

Defining the strategy is merely adding meat to the bones of the vision statement!

I would expect that before you start exploring the strategy in any detail the following has happened:

  1. Stakeholders have all been identified and there is a broad (high-level) RACI matrix in place for each party
  2. C-Level engagement has happened and there has been formal buy-in that the program is needed
  3. Terms of reference have been drafted and agreed by all stakeholders and outline budgets and business cases documented in full
  4. C-Level executive/committee has signed off the terms/ straw-man budget

If the above has not happened, then I would politely suggest you’re wasting your time and that of many others proceeding any further.

It is likely at this stage you will have conditional approval/buy-in from the executive committee and that to progress they will want to see a detailed strategic plan on what the program will bring to the business.

From a product data perspective, it is likely your firm is facing some (or worst case all) of the following challenges which probably led to the initial discussions around …”we really need a governance program to oversee the management and publication of our investment product data

  • A desire from a client servicing perspective to up the game when it comes to client communications so that investors have access to more timely data, more relevant data and a greater breadth and depth of information than is currently available today.
  • A realization that Dodd-Frank, Volcker, FATCA, AIFMD, UCITS IV / V, KID, Solvency II, the FSOC, the ESRB – all have a common thread – a demand for more transparency, a demand to share information that has not been shared before.
  • Demands from institutional investors to open the lid on reporting holdings in a timely manner (with not so veiled threats to pull mandates)
  • Demands from the sales/distribution team to deliver more timely and consistent information about products to just compete with competitor firms
  • High costs and lengthy lead-time to deliver technology solutions due to the evolution of a cottage industry of silos based on Excel macros and Access databases
  • Compliance team observation that certain investors have access to data about products which other investors in the same product did not receive – an issue for treating customers fairly
  • A concern that data is available to too many people who do not understand what they are “handling”, be that the sensitivity of the data, or the compliance and handling issues that could be connected to the data
  • Operations view that the process of sourcing, cleansing, storing and distributing client facing data is inefficient and error-prone
  • Compliance view that the client-facing data process is manual, non-systematic and has no audit trail
  • Challenges in the sourcing and maintenance of complex or very large data sets
  • A lack of oversight and general understanding that is leading to poor practises evolving un-checked
  • Increased regulatory change is changing the architecture of entire data environment

So, the program drivers along with the views of the stakeholders should form the evolution of the initial business requirement that will go on to form a clear strategic view of what the program is setting out to achieve.

There are many ways to express / communicate the strategy – think of how you would present a business plan – outline the goals and objectives clearly, break the goals down into stages and set them to a prioritized timeline.

Think about all of the activity that will need to happen to create a structured framework that can set about delivering the strategy:

  • Establishment of domain-specific working groups
  • Identification, agreement and documentation of the strategic business goals for the program
  • Identification and documentation of the policies that set the strategy in stone
  • Specification of the standards that will need to be agreed
  • Plans for how you will bring together the people, process and technology to deliver
  • Complete understanding and documentation of the data architecture for the data domain in scope
  • Requirements for oversight and control
  • Building out the processes and procedures for data quality management
  • Agreeing and delivering the KPIs that will allow you monitor the data quality management activities
  • Evolution of a data dictionary to ensure understanding of the data domain end-to-end
  • Identification of the Target Operating Model and the steps along the way to the future-state

So hopefully, now you will appreciate why you could be wasting a whole load of time and effort if you engage fully without having really clear buy-in at C-Level.

Next up I will discuss models for stewardship…


Setting up a governance program for effective management of investment product master data – Part 1 – Organization

January 15, 2013

It is not without reason that I chose “organization” as the first theme in this series of blogs on a blueprint for setting up a program of governance for effective management of Investment Product Master (IPM) data in an asset management firm – every firm is different. Each firm has its own unique blend of culture, history and esoteric business practices that mean that there is no cookie cutter type solution to implementing a program of governance for IPM data. This is why having a clear understanding of the mechanics that make your organization tick is a key element in kick-starting the activities needed.

Some key questions that need to be asked:

- Who in the firm cares about the quality of the product data being pushed into the market about your funds? I would expect the answer here to include at least someone at C-Level, probably the COO and potentially the CFO. I expect the Head of Distribution will care passionately about the quality and timeliness of information being pushed to prospective and actual clients. I expect the Risk/Compliance department to care – after all this is their job! I would expect various operational heads will have a keen interest – such as, Head of Product, Head of Performance/Attribution and finally, I expect that someone in the Treasury function whose role is oversight of back-office accounting data flows i.e. price and income would have a vested interest. For sure, there are others that belong in this group but I am trying to keep this at a high level.

- Is there one person or team in the firm who is directly accountable and /or responsible for the quality of information published about the firm’s funds and investment accounts? I often get a variety of answers here – sometimes you will find there is a data governance team and/or Chief Data Officer / Czar in place, but more often than not you will find their effective remit is actually quite limited in scope and the breadth of the data they are responsible for does not extend to your own Investment Product Master data – why is this? I think it is because firms believe this data, being their own, must be of good quality. The reality is that this data is often cobbled together across a disparate range of in-house silos, many of which are collections of Excel macros and Access databases, mixed in with some actual systematic feeds of data from systems that have not been manually altered. Sometimes, you will find that in fact there is a person or team with direct responsibility for the product data – quite often the Head of Marketing, or the Head of Performance.

What is the goal here? Well if you have found through your questioning that there is neither a person nor a team who is directly accountable, nor any team that is responsible – you need to work through the list of people who ‘care’ to create a initial committee or steering group to run your governance program. This is the most basic step – the formation of groups within your firm who will take the initiative and drive this forward.

Whether the program is managed by committee or by a specific person depends on the organizational culture – do whatever works in your firm. But, without a doubt,  this initiative will fail within weeks if you do not have executive sponsorship and full engagement from at least one C-level executive.

One thing I would stress – particularly if your firm already has a data governance function – if this existing function does not have a specific and obviously executed mandate to take and apply control to your investment product data, then set up a new team/program to take on this very specific mandate. Too often you will find that there is a broad program of activity in place – but that it is highly focussed on the investment books and records and the data/systems that are feeding into investment decisions made within the trading and portfolio management teams. There is often little or no focus on the product data that the firm is sending out to the public domain and on which the firm’s clients are making (or not making) decisions to invest in the firm’s own funds (or accounts).

Certainly if I were the Head of Distribution, Client Services, Marketing or Compliance/Regulation - this would be very high on my agenda. The sales and distribution engines need good quality and timely data to compete for new assets and retain existing clients. Remember my earlier post, data is the oil in the sales engine!


Setting up a governance program for effective management of investment product master data – Overview

January 11, 2013

I am planning a series of blog entries on a blueprint for setting up an effective program of governance for investment product data – this will be of interest to companies who might be considering implementing a solution for investment product data management – or – who might be supplementing an existing EDM data governance program with investment product information – or – who are looking on building out a program for the first time.

While the blog will be primarily focused on investment product data, it will be possible to derive valuable insight for other data types within asset management or in alternative verticals.

The following are the 10 themes I will cover over the coming weeks….

  1. Organization
  2. Terms of Reference
  3. Defining the Strategy
  4. Model for Stewardship
  5. Standards and Policies
  6. Process and Procedures
  7. Master Data Plan
  8. Data Dictionary
  9. Technology Frameworks
  10. Move to Maturity

Q3 2012 – Webcast survey results – update #2

September 10, 2012

This is a continuation of the last post on the results of the recent survey from my latest webcast.

The second question in the survey asked “Would you say the investment product data that you distribute is good quality?” The results from this question were a real eye-opener – only 29% of respondents believed their investment product data was good quality.

One has to consider this alongside the answers to the first question “Do you have a formal data quality management process for client-facing data?“, where 58% of respondents indicated in the affirmative that they did have a formal quality process in place for client-facing data.

So if we assume that those who responded YES/ALWAYS to the second question also responded YES to the first question, then one could (loosely!) infer that while many firms have gone to the effort of putting in place a formal process to govern and manage client-facing data, only half of those firms believe that their process is truly effective.

What is somewhat alarming is that 43% of the respondents to our second question believe that their client-facing data is only good quality some of the time, while a further 7% believe it is not ever good quality – that is a fairly shocking result – think about it…..50% of respondents believe the data that they put in front of their clients pre- or post- investment is only good quality some of the time and in some cases is never good quality.

I believe this highlights the fact that the focus that is coming to play on investment product data is very much early-stage and the maturity of the processes that are being put in place is not fully there to deliver the repeatable quality results that will only come when the programs have delivered a fully mature process – I did a post a while ago which casts light on the data management maturity models that explains this point in detail.

In my next post I will consider the results we had for our third question “Which regulation is causing you most concern?

So long…


Recent webcast survey results

September 5, 2012

For anyone who attended our webcast in July (The Impact of Upcoming Regulation on Data Management), you will be aware we conducted a survey during the webcast which asked the following questions:

  1. Do you have a formal data quality management process for client facing data?
  2. Would you say the investment product data that you distribute is good quality?
  3. Which regulation is causing you most concern?
  4. What is your biggest challenge in getting your investment product data to market?

The results were really interesting and I did promise I would post a review of the feedback – so here it is….

For question #1 “Do you have a formal data quality management process for client-facing data?” the results were really encouraging, with 58% indicating that YES they did have a formal data quality management process for client facing data – I say this is encouraging because not too long ago the core and sometimes sole focus of data governance programs was on the foundational layers of the EDM process in the middle-office  i.e. security and reference master projects, trade reconciliation, shadow accounting, and so forth – now the focus is clearly switching to include the data that asset managers are pushing into the public domain, the data that describes their own products and which is used to market, sell and position their products to the investor community – the Investment Product Master.

So while there will always be a strong requirement for governance programs to oversee and apply structure to the systems on which business intelligence is dependent  and which support the internal function of an asset management business – there is a clear realization that the information that the organizations are putting in front of clients requires equally high levels of attention.

Something else to note is that this is not a “fear-led” strategy i.e. it is not the fear of regulatory scrutiny and public sanctions that is driving this to the fore, it is in fact sales and distribution that are focussing the light on investment product data, as there is growing awareness that high quality and timely product data is a key driver in maintaining AUM and grabbing an even greater slice of available inflows – remember data is the oil in the investment sales engine!

In my next post, I will consider the results to the second question in the survey “Would you say the investment product data that you distribute is good quality?

BTW If you missed the webcast – there is a playback link here


Webcast available for on-demand playback…

August 10, 2012

For those of you who missed the recent webcast on regulation and its impact on data management strategies in the investment fund world, it is available for playback here


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