Marketplace transparency and reporting readiness

Posted by Irena Gecas-McCarthy, Advisory Principal, Deloitte & Touche LLP, David Wright, Advisory Managing Director, Deloitte & Touche LLP, Dmitry Gutman, Advisory Managing Director, Deloitte & Touche LLP, Dilip Krishna, Advisory Managing Director, Deloitte & Touche LLP,  Ken Lamar, Independent Senior Advisor to Deloitte & Touche LLP, Richard Rosenthal, Advisory Senior Manager, Deloitte & Touche LLP, Claudio Rodriguez, Advisory Senior Manager, Deloitte & Touche LLP, Pranav Shanghvi, Advisory Senior Manager, Deloitte & Touche LLP,  Mike Thakkar, Advisory Senior Manager, Deloitte & Touche LLP, and Alex LePore, Advisory Senior Consultant, Deloitte & Touche LLP on August 10, 2016

Introduction

Federal Reserve Board (FRB) officials have made clear in communications with the industry that they expect the foreign banking organizations (FBOs) similar to the US bank holding companies to have the capabilities to access and provide high-quality data, including credible internal reporting/MIS and regulatory reporting data from the outset.1  They point out that FBOs have had more than three years to come into compliance with enhanced prudential standards (after the initial rule proposal) and believe that effective internal MIS and regulatory reporting processes should be in place by now.  This expectation—coupled with increased transparency provided by the public disclosure of several regulatory reports—places pressure on FBOs to ensure that their end-to-end data production processes and control frameworks produce accurate and complete reporting.  There are additional regulatory reporting requirements that have been proposed and will be finalized as the industry comment periods end and the FRB processes are finalized.  These include the attestation of the FR Y-14 reports for the FBO Intermediate Holding Companies (IHC).

Building clear process and control documentation, data governance, and quality assurance processes are critical to demonstrating credible MIS and regulatory reporting implementation.  Establishing confidence in reporting will be especially critical to meeting IHC capital planning expectations related to the April 2017 Comprehensive Capital Analysis and Review (CCAR) submissions (the non-public “dry run”). The bar is high.  FBOs face reputational risk as a result of the increased transparency provided by the public disclosure of regulatory reporting filings (most notably the FR Y-9C, which will disclose IHCs’ capital ratios, balance sheet information, and financial performance, among other information, as well as public disclosure of CCAR results).

Continue reading “Marketplace transparency and reporting readiness”

On SDR reconciliation, energy companies find reasons to exceed requirements

On SDR reconciliation, energy companies find reasons to exceed requirementsPosted by Mike Prokop, Director, Deloitte & Touche LLP

At a panel discussion I recently facilitated on swap data repository (SDR) reconciliation, fewer than half the energy industry attendees said they have a solution in place for that function. Still, at least one participant said reconciling data in the SDR is a good idea because it enhances end-users’ understanding of the information being reported and serves as an internal risk mitigation measure. Our October 3, 2014 discussion was part of Deloitte’s Dodd-Frank Compliance Leadership Academy.

Continue reading “On SDR reconciliation, energy companies find reasons to exceed requirements”

In compliance data, quality rivals quantity

Energy companies eye compliance monitoring; panel advises close ties with businessPosted by Paul Campbell, Principal, Deloitte & Touche LLP and Howard Friedman, Director, Deloitte & Touche LLP

“Our best metric is still a gut feel.” That’s how one panelist summed up his company’s approach to making sure its compliance program provides the most useful feedback.

That comment was part of a panel discussion on compliance data benchmarks we facilitated on October 2, 2014 as part of Deloitte’s Dodd-Frank Compliance Leadership Academy. The participants were eager to get in front of compliance trends so they could apply the indicators today they’ll need to report on tomorrow. And while many of those indicators arise directly from the compliance function, we found it’s just as important to keep abreast of operations-related data, such as the management of physical assets.

But first, back to that “gut feel.” One theme that ran through our discussion was the need to take a broad view of what constitutes useful compliance data.

Continue reading “In compliance data, quality rivals quantity”

Responding to Medicare’s New Short Stay Rules

Responding to Medicare's New Short Stay RulesPosted by Kelly Sauders, Partner, Deloitte & Touche LLP

The issue of short inpatient stays is probably the biggest Medicare challenge that hospitals currently face. This issue has been an ongoing challenge for years, but until now many hospitals didn’t know how to tackle it ¬ or didn’t think they had to. That all changed on October 1, 2013, when the Centers for Medicare & Medicaid Services’ (CMS) new ‘2 midnight rule’ went into effect. Now, it’s clear that a hospital stay must include two midnights in order for associated services to be classified as inpatient. This rule change has tremendous financial and operational implications and should be addressed immediately. Hospitals that continue to ignore the problem are at significant risk of facing more and more Medicare denials. Here are five steps hospitals can consider taking to help address this risk:

Continue reading “Responding to Medicare’s New Short Stay Rules”