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….


Financial Technologies Forum LLC – FATCA Kills the Data Silo?

February 4, 2013

Interesting article on FTF about FATCA….Financial Technologies Forum LLC – FATCA Kills the Data Silo?.


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…


How will daily NAV disclosure impact money funds?

January 29, 2013

As posted in Ignites Q&A of the week on 25th January, I thought I would share my response here

What is the potential impact on the industry now that some mutual fund firms are starting to disclose daily NAVs for their money market funds?

Scrutiny of money market funds has never been more intense, and the industry must prepare for further changes to the regulatory regime. Specifically, daily disclosure of money market funds’ net asset value (NAV) has become a reality, and that will have ripple effects throughout the industry.

Some of the key players in the money market fund business have taken a pre-emptive move to provide the transparency that regulators and investors have been demanding since the Reserve Primary Fund broke the buck in September 2008.

The daily NAV disclosures are obviously a step toward improving fund firms’ client services to investors. Clearly, it will benefit investors by increasing transparency and helping them to better understand money market funds and their risks. But there will be operational and compliance challenges coming from this trend that fund firms must consider. Some of the measures firms will have to implement include the following:

  • Reassess existing investment processes. Fund firms will need to reevaluate their investment process to ensure that the daily shadow NAV does not materially deviate from the buck;
  • Strengthen data-reporting process. They will need to ensure they have a systematic, auditable and repeatable process for distribution of the data to market; and
  • Reevaluate communications strategy. Fund firms will need to reevaluate how they communicate the NAV to the market and gauge any potential impacts on their marketing and regulatory documents that are in the public domain.

Daily disclosure of the NAV for a money market fund gives investors the reassurance that the fund manager is committed to being transparent and open about the current state of the fund. In the past, most money managers were distributing this data monthly, which led to a level of investor angst that the fund manager was not always showing all their cards.

The breadth of securities that money market funds invest in means that each holding can have multiple levels of credit exposure, and so for many, transparency is a must.

In order to deliver the NAV daily, firms need 100% belief in their investment process. The shadow NAV must not deviate materially from the buck on an intra-month basis. Firms that are publishing daily NAVs will most likely guarantee redemptions at the buck if the shadow NAV drops below the buck.

Beyond daily NAV publication, I expect to see more announcements from asset managers on moves toward becoming more transparent in other areas as well. One of the key demands from regulators and investors is the timeliness of the publication of portfolio holdings.

Current practice sees most managers publishing data quarterly, with some publishing monthly. However, in nearly all cases, the data is embargoed or time-lagged to prevent front-running and free-riding. There is considerable pressure being brought to bear by institutional investors and regulators to increase frequency of publication to monthly across the board and reduce the embargo periods. Some asset managers are preparing for a situation where they believe ultimately a daily reporting of holdings will be demanded.

One of the biggest obstacles to becoming more transparent can be the exposure to manual processes. Fund product data comes from a variety of different sources and has to be checked and double-checked before the information can be released. An organization that validates its product data at the source and stores it efficiently can ensure it is always ready for publication. It is vital for fund firms to get their product data to market on a timely basis, ensuring it is always accurate and consistent. That includes daily money fund NAVs.

Firms must also consider the impact on marketing and regulatory documents that they distribute to the market, including their own website, in the context of any data reporting trends. Additionally, they should review how the external distribution networks, platforms, broker-dealers and other intermediaries will be impacted by any change to daily publication on short notice.

I am delighted to see this move toward transparency represented by the daily disclosure of money market funds’ NAVs.

We are going to hear more and more about investor and regulator demands for more information as the pressure to deliver transparency continues to grow. The overriding themes in asset management for the next 10 years will involve transparency and risk.

To adapt to the current environment, fund firms, especially those offering money market funds, should reassess existing investment processes, strengthen their data-reporting process and re-evaluate their communications strategy.


On Regulation: AIFMD

August 15, 2012

The AIFM (Alternative Investment Fund Managers) Directive, which is focussed on improving transparency in the alternative investments market place, is coming soon.

ESMA published its final technical advice on the 16th of November 2011, with the deadline for transposition into national law happening in July 2013.

Getting ready for AIFM requires managers, and to a lesser extent depositories, to start taking action as soon as possible. Many of the key players in the market have already carried out high level impact assessments and operating model reviews, and although ESMA’s approach on reporting frequency was welcomed, specifically how they propose to relate reporting frequency to ‘fund and firm’ AUM, there was disappointment with the failure to change the substance of the reporting and the 1-month deadline for reporting  (note: fund of fund structures will have an extra weeks).

So what is the directive looking to achieve? Well, once registered with their national regulator, firms will be required to offer enhanced disclosure on their risk management program and open the lid on their investment strategies. The key element here is increasing transparency and oversight, so that the regulator can monitor exposure to systemic risk, and make sure investors in the alternatives space are being treated fairly.

In addition, the industry is going to be forced to provide more data to investors in advance of, and post any investment in the funds concerned. The disclosure to investor requirements relate to any change in liquidity requirement, risk profile, disclosure of risk management processes and disclosure of % of assets that are subject to special arrangements.

ESMA’s approach to leverage has attracted a lot of attention and public commentary. ESMA is proposing more regular disclosure requirements to investors which would cover changes to the maximum level of leverage, to the rights of re-use of the collateral, to the nature of guarantees granted and of the total leverage employed in the portfolio and their business as a whole.

The directive also requires firms to maintain up to date data on the securities they are trading, including standards based support for security identification, with additional details required on principle exposures and risk concentration.

Depositories will be required to monitor and request data from funds, and to perform additional due diligence on the custodian and prime brokers.  All players in these markets will therefore be compelled to invest in their risk and data management infrastructures, and product data (holdings, classifications, portfolio allocation views)  must be quickly accessible for reporting purposes. This activity is driving many firms to re-assess their data management strategies, infrastructure and operating models so that they are positioned to react when the regulation comes into full force in less than a years time.


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


Webcast: The impact of upcoming regulation on data management

July 18, 2012

I am hosting a webcast on “The Impact of Upcoming Regulation on Data Management” on Wednesday 25th July 2012, 3pm BST, 10am EST.

Regulation is a key challenge in the industry and in an unprecedented age of openness and transparency continues to be the no. 1 driver for asset managers investing in data and reporting initiatives. Companies want to mitigate the risk of inaccurate information being in the public domain and many are embarking on data management projects – which will save time, reduce errors and automate processes. The key themes we see center on capability to deliver a systematic, repeatable and auditable data publication process for client-facing data.

This webcast will be presented by myself, and will focus on how upcoming regulations will impact the industry and how asset managers need to prepare to ensure they stay ahead in a highly competitive market. Specific topics to be covered include: the latest version of AIFMD, the final throes of the Retail Distribution Review, the latest on KIID for PRIPS, UCITS V, how being important or “SIFI” is no longer so desirable, Volcker, FATCA and last but certainly not least Pillar III of Solvency II.

Finally, I will touch on what is around the corner and run through some recommendations with respect to preparing for the swathe of upcoming regulatory change.

To register for this webcast please click here.

I look forward to welcoming you online on July 25th.


Making the most of your data

April 10, 2012

We all talk about how important data quality has become, how important it is to deliver transparent, high quality information to our customers, and how that’s been driven by regulation and by changing investors. However, I’ve been at a number of events recently, and talking to customers and prospects about data management and I think that the stakeholders in data management projects have changed – it used to be technology, now it’s predominantly the business.

The drivers for these initiatives have moved beyond improving operational efficiencies – now it’s about improving your client service and your customer experience by sending out high quality data, and it’s about how you use that data to promote your messages as well.

It used to be all about getting the data in one place and it was all manual processes – in many organizations the processes are now automated, they can get the data faster and they have time to analyze it and use it for marketing. Wouldn’t it be great to link your sales data to your fund data so when you have news about one of your funds, you can push it out to the sales force so they have immediate access to that information for their customers … or you can push it out to your marketing department so they can immediately execute a targeted campaign to a particular group of prospects. You could really add value to your organization’s sales processes by leveraging the information in your product data…and connecting it to your advisor and customer data …and then tying it all back together with your books and records data flowing from TA.

Many asset managers have empowered their sales teams with iPads so that they have access to all the latest product information … anywhere, anytime. At NICSA’s recent conference in Miami, it was revealed that 76% of advisers share content online (up from 67% in 2010). This includes performance information, white papers, commentaries etc…. it underlines the importance of being able to provide that information, ensuring that it is always accurate.

There is no point having all these silos of business intelligence in the distribution front-office if you cannot leverage it – make the most of your data!


Where are you on the Data Governance evolution scale?

February 27, 2012
This post was recently published on TABBFORUM (21st February)

Just about every asset management firm now claims to have a formal data governance process in place – in fact if firms aren’t saying this we should be worried indeed. So while all data quality management governance processes may be created as equals, they are very rarely at the same point of evolution – with the bottom of the evolution scale being a million miles from the top-end fully evolved processes.

In the diagram below you can see that processes in the early stages of evolution start as chaotic processes, with often low levels of standards and formal operating procedures, with very little sign of an obvious ‘master plan’  or strategy.

Data Governance Evolution - from Chaotic to Predictive

The Data Governance Evolution Scale

In order to move to the next stage on the evolution scale, you need to establish standards, you need formal operating procedures for data stewards such that a semblance of an operating data quality management process starts to take effect with a strategy and master plan identified and communicated to the applicable stakeholders.

The mid-point in the evolution scale is achieved when the process can be accurately described as defined – that is where you have identified key performance indicators that show the health of your process, where you have documented artefacts such as a data dictionary and rules dictionary, where you can show you have stewardship operating across the breadth of the data creation to data consumption processes, with applicable technology frameworks in place to support stewardship of the governance with key processes like root cause analysis being tracked and measured.

Very few firms have moved past the ‘defined’ stage in the evolution process. Getting to the next stage ‘Pro-active’ requires serious attention and investment and very often monumental cultural re-alignment. Pro-active governance is achieved when you can demonstrate a cast iron continuous improvement cycle, with error feedback loops constantly leading to process improvement – very much in the model of six sigma – in fact many firms who have attained this level, do so under the auspices of an investment in ISO9000 or Six Sigma. At this point of evolution, the firm is applying automation across the board to root out the manual human errors that plague many firms today. Key to the approach is a unified governance approach to how data is managed across all of the data silos in the firm.

Finally, you have reached the nirvana point of evolution when your data quality governance has become what many refer to as ‘Pre-dictive’. At this point of evolution, not only is the process fully automated, it also has a fully demonstrable audit trail that fosters accountability and ownership. The top-down strategy is fully in tune with the bottom-up application of the strategy, with complete cultural alignment across the breadth of the firm, effectively with the people, the process and technology all working in harmony. At this point, your process feedback loops are fine tuning, rather than fixing.


Data at your Service

February 2, 2012

Ever wondered how you can improve client services? I would argue that easy access to timely, accurate and ultimately reliable information about your products i.e. their investments, being delivered through an effective data governance programme, is a key enabler to service excellence. Arguably, the main differentiators for investors in terms of client services are the timeliness and quality of Investment Reporting coupled with a responsive and assured service that they can rely on if they wish to enquire about their investments. In the age of transparency, there is no room left for complacency in these areas.

Timely and Reliable Investment Reports

Strong data governance coupled with effective stewardship enables shorter reporting cycles therefore providing your clients with their investment reports earlier and exceeding their expectations for up-to-date information on their investment portfolio. However, timeliness of delivery will not do it alone. It has to go in pair with reliable data. The validation process in a data governance programme ensures that you get it right the first time; which in turn will save time by removing the iterative process of checking, correcting and rechecking reports. Clients do not only expect to receive reporting on time. The content has to be complete, accurate and consistent for it to deliver value.

Finalising reports earlier also provides your client service team with more time to focus on adding value when delivering the information by analysing the data and preparing to review the investment report with or pre-empt questions from their client.

Assured and Responsive Client Service

In the current environment and under increased regulatory scrutiny, asset management firms are adopting a fiduciary mind-set and strive to be as transparent to their clients as possible. Therefore, your customer service team’s ability to navigate your product data and have timely and accurate information at their finger tips is critical to your success. The changing regulatory landscape requires customer service staff to ensure they are prepared to address any question or concern that an investor may raise in a responsive and knowledgeable manner. Therefore, conveying confidence, building trust and making the investor feel that they are in good hands.

A strong data governance system will empower client services to achieve these high standards by building their own confidence in the information that they source internally, by providing them with the most up-to-date data and by allowing them to quickly identify the owner of specific data points to route investor enquiries to the right source of expertise within your organisation.  Therefore, helping them to get the answer right the first time.


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