IHC Transformation: Developed a CCAR Regulatory Program to Address Operational Readiness for Capital Planning, Modeling and Data / IT Capabilities
Background
When a global bank was in the process of establishing an IHC (Intermediate Holding Company), it requested Wavestone’s support in driving the development and implementation of its newly developed CCAR program to ensure all regulatory requirements are captured and delivered across their IHC platform. Additionally, the CCAR program needed alignment of the firm’s existing BHC (Bank Holding Company) with the soon-to-be established IHC, requiring Wavestone to design and implement a strategic Target Operating Model that would account for the efficiencies and dependencies across transversal banking operations, specifically Risk and Financial/Regulatory Reporting.
Challenges
- Interdependency of Program Work Streams & Regulatory Reporting – An extensive scope of 40+ CCAR cross-functional projects required a significant degree of alignment and coordination to build new capabilities across the platform and meet regulatory reporting requirements
- Parallel Development of Production & Contingency Plans – While the primary focus was Day 1 delivery of the process and capabilities for the IHC go-live and first non-public filing submission, contingency planning was also needed for FR Y-14Q and 14A report production, requiring Wavestone to implement a systematic and analytical approach
Answers & Key Success Factors
- Developing an extensive Program Management Office to manage the complex scope of activities and functions when creating a brand new, all-encompassing Regulatory Reporting Program
- Coordinating a comprehensive analysis of regulatory considerations and industry best practices to ensure effective implementation of regulatory programs, while in parallel, ensuring that the project can adapt to evolving regulatory requirements
