Expert Dialogues: Harnessing Managed Services to Optimize Upcoming Rewrite Changes
The final rules published by the Monetary Authority of Singapore (MAS) on 31st May 2024 came as no surprise as the industry has been in discussion for as early as two years ago. For MAS and ASIC reporting firms in scope, we are now less than 3 months away from the 21st October deadline. Over the past few months, we have also had firms engaged with Cappitech to examine their existing reporting workflow leading up to the October compliance date. We sat down with Chung Shern Yen, Director, APAC Managed Services and Consulting, at S&P Global Market Intelligence, Cappitech to discuss more on this.
With the final rules published by the regulator, could you share what this means for our clients?
Chung Shern:
Firms were encouraged by industry to begin their preparatory work based on the near-final amendments as early as last year. Subsequent FAQs and guidelines published by MAS show minimal material changes but offer increased clarity through enriched explanatory notes for Critical Data Elements (CDE) fields. This also meant that firms are recommended to be at a stage where they are armed with a project implementation plan to address all the required changes, supported with sufficient staff and resources for testing, training and mitigating outstanding issues. At this juncture, it is worthwhile to step back to assess a company’s overall readiness. Here are some actions for consideration:
- Conduct robust UAT and regression testing: Create a comprehensive test plan that addresses all aspects of the changes, ensuring sufficient resources for User Acceptance Testing (UAT). Prioritize early identification and resolution of issues to allow ample time for fixes before go-live. Additionally, emphasize regression testing to ensure that system upgrades do not adversely impact other processes.
- Plan for Contingencies: Conduct regular pulse checks and assessments of issues during UAT, ensuring sensible risk-based prioritization. Develop a contingency plan to ensure a compliant and timely go-live with minimal disruptions.
- Transparency on Implementation Plan: Finalize and communicate all aspects of the plan across relevant stakeholders, including go-live activities and their potential impacts, post go-live status checks, identifying potential risks, and establishing protocols to address any issues promptly.
- Staff Readiness and Process Update: Conduct comprehensive training sessions and update process documentation on regulatory changes, revised BAU processes, enhanced exception monitoring, updated investigation steps, and new control measures to ensure staff readiness and compliance.
How are some clients using Cappitech’s Managed Services?
Chung Shern:
To help our clients address their regulatory requirements, we assist them as comprehensively as we can from detailed project planning and task scheduling to developing customized testing strategies and go-live plans. On the business analysis front, we deliver documentation on data requirements and plan for the integration of new data sources. Additionally, operational best practices have also been a repeated topic from clients so we would provide such guidance to help them navigate compliance challenges while tailoring our offerings to suit an individual client’s needs.
Can you share an example?
Chung Shern:
A client approached us as they encountered a few challenges – namely due to tight internal timelines, resource constraints, lack of regulatory subject expertise and uncertainty of their current reporting processes. They wanted a second opinion as they were unsure if their existing build will be compliant for their October go-live date.
We offered operational subject matter expertise to conduct a gap analysis on their current reporting process, evaluated the break down to root cause and proposed recommendations to close out gaps. For example, we observed that the client’s current MAS reporting is not robust enough and mostly based on European Market Infrastructure Reporting (EMIR) stack. This could have resulted in questions raised by its internal compliance. On its health assessment, we took a systematic and structured approach to assess the client’s current reporting framework and its compliance against regulatory standards and Cappitech metrics. Additionally, we collaborated closely with the client to implement workflows introduced by UTI and UPI, focusing on exception management and data sourcing.
We then benchmarked the post-diagnosis changes against our best practices to ensure the client is confident with the improvement. Apart from the paramount task of documenting these changes, we also provided recorded training to the staff to make sure our client staff holds accountability to maintain oversight of the reporting business.
Lastly, we partnered with the client to execute sampling data testing to ensure completeness whereupon discrepancies were promptly remediated to ensure accuracy in this function. Additional controls to encompass front to end of the reporting workflow were also provided for client adoption.
Thank you for sharing. As a closing remark, please share 3 takeaway messages for clients as they advance into the last lap of this journey.
Chung Shern:
- Prepare for Day 1 now – this includes documentation, and fallback plans to tackle what-if scenarios.
- Don’t overlook minor details.
- Continue to keep all stakeholders involved and updated.
Contact us to learn more about Cappitech Managed Services.
