During its most recent firms forum on the subject of liquidity reporting, the UK Financial Services Authority (FSA) confirmed that it is planning a soft launch for liquidity risk reporting on its online regulatory reporting system, Gathering Better Regulatory Information Electronically (Gabriel). As noted by the FSA in January, firms are being required to test the submission process for their data items to the Gabriel system, but the regulator has backed off from pushing data quality tests by delaying these for another three months.
“We have concluded, from dialogue with firms’ IT departments and our own internal systems developers, that to ensure adequate systems robustness a soft launch of Gabriel is the most appropriate way forward,” said the FSA’s Chris Stoddart at the 18 March meeting.
This soft launch will focus on two reports (rather than three as previously intended): FSA047 and FSA048. It will be conducted between 1 June and 3 September, during which time the Gabriel system will be available for testing purposes. The testing of FSA052 has been deferred until 3 September and the FSA indicates it will not be launching a thematic investigation into the data quality of these reports until after the testing period has ended, thus affording firms more time to fine tune these reporting processes.
The FSA notes that participation in this testing process is “voluntary” but warns that firms should take the opportunity to participate: “We give firms the opportunity to prove to themselves that their data processes and systems will be ready for when we switch to the Gabriel submission path for regulatory returns from 3 September. We therefore encourage firms to submit via Gabriel, on a regular weekly basis.” A veiled threat if ever there was one.
However, the regulator has gone to great lengths to stress that it will not take any punitive action against those firms that submit “rejected or incompatible” reports during the testing period. In terms of the detail of these reports, they must be submitted in spreadsheet form but separate returns must be provided for each material currency and on the solo or defined liquidity group basis if the firm has been granted a waiver.
The timetable for submission and testing of FSA052 reports will be confirmed on the regulator’s website shortly, it states.
The testing process for the first wave of firms is well underway and three firms and two software vendors participated in the first round of desk checking in January and February. According to the FSA, during this period 29 data items were received and processed through a schema editor and the test system. “This provided more thorough testing and feedback,” noted Stoddart.
The validation checking process is now underway until April, during which time vendors and firms must email their data to the FSA, which will then be run through a test environment and returned back to these firms. The FSA indicates that 17 firms and vendors are part of this liquidity reporting validation testing process and 40 data items have been processed thus far.
The end-to-end testing process for Gabriel will begin in May and will involve the submission of data to a fully operational test model of the system. The FSA notes that bookings for this phase of testing are now closed and 17 firms have confirmed their participation. “We aim to publish the plan by the start of April. Due to the interactive nature of this testing – it will have to be tightly controlled and we will have to be very strict on the allocation of testing slots. Although we do appreciate the need that multiple iterations may be required,” said Stoddart.
The slides from the March meeting are available here.