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MAS 610

The extent of change in terms of data-points to be reported is ginormous. Both domestic and foreign banks will have to report 300,000+ data-points across 66 reporting forms compared to 4,000+ data-points across 19 reporting forms in the current version of MAS 610.

 The MAS 610 reporting changes apply to all commercial banks operating in Singapore irrespective of the nature of their banking license.

The two most notable changes in the proposed revisions to MAS 610 are the increase in the granularity of reporting and the requirement to report financial positions by multiple dimensions. Banks will need to conduct a data-gap analysis to check whether they are already capturing data at the required level of granularity and whether all the attributes related to reporting dimensions are also being captured. Data gaps, if present, will necessitate upgrades of multiple source systems.

Yes, there will be a parallel run for 6 months starting from March 31, 2020.

The reporting as per the revised MAS 610 guidelines will commence simultaneously for all 66 reporting forms from March 31, 2020. However, banks must continue to report as per the current MAS 610 guidelines in parallel up to September 30, 2020.

All banks will be required to update MAS on their progress every six months. The updates should include any issues faced by banks as well as action plans to address those issues. In addition, banks will also need to work with an Industry Working Group which will be set up by MAS and ABS to identify common issues and requirements across banks and to propose solutions to such issues and requirements. 

Data Preparation

These are the some of the new data requirements as per the revisions:

  • Top-level Financial Positions: Reporting sought for Assets held within Special Purpose Entities, Customers’ assets under management and Customers’ assets under custody.
  • Interbank exposures: Reporting sought for contingent liabilities and commitments, Identification of counterparties related to reporting bank, Grouping of exposures to financial institutions within the same business group etc.
  • Exposures by country & counterparty type: Reporting sought for contingent liabilities, commitments, and financial derivatives, Separate reporting of exposures to immediate and ultimate risk counterparties, Currency-wise reporting, Increase in country count etc.
  • Exposures by sector: Reporting sought for financial derivatives, ~25% increase in sector count, Separate reporting for Project Finance loans, Split between Secured Vs Unsecured portions etc.
  • Exposures by purpose: Reporting sought for contingent liabilities & commitments, Increase in the number of Purpose codes etc.
  • Asset aging & classification: Reporting sought for commitments, Reporting by country, ~200% increase in sector count, Ageing analysis by purpose of lending etc.
  • Miscellaneous: Reporting sought for Inward and Outward Wire Transfer volumes, Financial derivatives by country of trade and by country of booking, Separate reporting of Commodities Derivatives etc.

The granularity in reporting assets, liabilities, contingent liabilities, and commitments is uniform across MAS 610 reports. The counterparty types, counterparty countries, counterparty sectors,purpose of lending, asset classifications etc. are also defined consistently across reports. So, banks should be able to reuse configurations across multiple returns. Some of the definitions, such as the definition of ‘secured credit’ which ignores Guarantees, Letters of Credit, or other intangible assets available as securities, are specific to MAS 610 and will necessitate creation of new business logic and related configurations.

Cloud and Information Security

Yes, there will be a parallel run for 6 months starting from March 31, 2020.

Argus has partnered with IBM to provide an extremely secure environment that ensures the safety of your data and prevents malicious attacks. Every client will have a unique URL and is redirected via a secure web gateway that can detect any impersonation, fraudulent access etc. The entire installation will have a second firewall placed to prevent accesses from potentially dangerous IP zones. In the further interest of security, we ensure that a separate instance of our market-leading platform is provisioned for each client – that eliminates any chance of data leaks.

The Argus cloud is built to have inbuilt business continuity. The cloud platform provides for the ability to have a mirror environment that can be brought up in quick-time. Further, pre-scheduled weekly/monthly backups are created to be able to restore to a “point in time”, anytime!

To ensure complete compliance to local regulatory laws and data privacy, the cloud installation of this solution is hosted locally, within Singapore. No data leaves or moves out of the geographic boundaries of the country!

Multi-factor authentication is part of our product roadmap, but currently we support a password configuration policy which allows the subscriber to enforce its password policy - Configure complexity of passwords and Enforce resetting frequency for passwords.

We use ‘sftp’ protocol which does data encryption during transmission and ‘https’ to ensure data is secured during application access. Additionally, we store the data on a standard RDBMS, eliminating the need for any additional encryption.

The subscriber can download the data via reports/screens that the application provides within the notice period of termination. Post discontinuation of service, both the data, as well as the application instance provided for the bank, will be destroyed.

Application

Our solution has an in-built ‘Data Profiler’ tool which can be used to detect possible issues with data at the time of loading. This tool is equipped with mathematical, logical, and relational operators using which users can configure and run various checks on data at the time of loading. The checks include but are not limited to, checks on variances with respect to data from a previous upload date.

Our solution is equipped with unlimited levels of the drill-down framework which allows easy navigation from reported fields to their driving components. The solution offers the following features:

        1.Direct one click drill-down from any cell on the report

        2.Drill-down on a specific report line item to access all the underlying granular data

        3.Drill-down at Rule Level, Account Level, Transaction Level, and GL Level

        4.Drill-down and download the underlying data tables, where applicable

        5. Export downloaded underlying data tables to CSV files

Yes, our solution allows users to adjust data before report submission. Users can directly adjust the data-point being reported or they can adjust various attributes at the contract level. Our solution also allows users to adjust GL balances to overcome data quality issues at the source systems. Users can capture comments against adjustments made and use an approval workflow for review. The solution maintains full audit trail for all adjustments made and generates a summary

Our solution has a user-friendly interface with in-built mathematical, logical, and relational operators using which users can set up validation checks between report line items, both within and across reports. Specifically, users can perform the following functions using this utility:

        1.Set up validation checks to check for mathematical and logical relationships between data points

        2.Configure actions ranging from raising alerts to stopping submissions in case of errors

        3.Track and stop submissions based on pre-defined Standard Deviation and Variance levels

In addition to the above, the solution comes with pre-built validation and reconciliation checks across MAS 610 reporting templates, as specified by the Monetary Authority of Singapore.

Our solution has an in-built ‘Review Process Flow’ engine which provides a GUI with a drag-and-drop tool for creating any number of user-defined workflows. The workflows are completely parameterizable with no limit on the number of levels in the approval process. Workflows, once created, can also be easily modified to include new users, user levels, and even to change the functions performed by any roles. The users can check the status of approval of reports and monitor changes made to reports during their journey through the approval workflow using a Task Calendar Screen with configurable access rights.

Our solution provides a user interface for managing user creation, role creation, role assignment, and privilege assignment for accessing various reports and artifacts

Implementation

All banks who subscribe to Argus’ cloud-based MAS 610 reporting service will receive a walk-through of Argus’ Data Reception structure. Banks will then need to use Argus’ Data Integration layer to load the mapped data extracts from their source systems into Argus’ Reception Area. Banks will also receive a Functional Specifications Document providing details about a comprehensive set of pre-built data profiles on internal reporting taxonomies (derived dimensions) covering all reporting fields. Banks will then need to configure business conditions as applicable by leveraging the input reporting taxonomies and load the configured data into Argus’ Data Mart for consumption by pre-built reporting rules. The solution will automatically generate all the applicable MAS 610 templates for the reporting date.

A typical implementation timeframe for MAS 610 will be 9 to 12 months, once the bank has augmented their source systems with missing data fields.

The following are the critical success factors to comply with the stated timelines:

       1.Conducting a data gap analysis and augmenting the source systems with missing data fields

       2.Being able to robustly map data extracts obtained from various source systems into Reporting                    Taxonomies

       3.Starting early

Banks can validate system generated returns in the following ways:

        1.Using configurable rules for reconciling both within and across reports

        2.Using report drill-down feature to review details at the most granular level

        3.Using system-generated worksheets which provide step-by-step computation details for                             exposures, collateral apportionment, and facility apportionment

Post implementation

Argus will ensure there are no errors and/ or omissions resulting from incorrect business logic used for creating pre-defined internal reporting taxonomies as well as incorrect pre-built rules used for generating the returns. However, the subscriber/ bank shall have checks and balances in place to avoid any errors and/ or omissions resulting from poor data quality, incorrect data mapping, incorrect configuration of business rules etc.

 

Argus constantly monitors updates or changes released by regulators and updates its pre-defined internal reporting taxonomies as well as pre-defined rules for report generation. All such product updates driven by regulatory changes will be released to Argus’ clients independent of software upgrades/ releases.

With the Argus’ cloud-based MAS reporting service, each customer will be covered as part of our Annual Maintenance Agreement with pre-defined SLAs covering fixes for defects in the core platform and solution features and access to updates and upgrades, as available. Such support will be available as per the business hours & calendar in Singapore.

Pricing

The Argus’ cloud-based MAS reporting service follows a self-explanatory annual pricing model which shall be provided basis the definition of project scope, size and scale of operations, number of users and any other specific determinant (as per the bank). The applicable annual pricing is inclusive of the Software License & Annual Support.