Independent review and analysis

Data held by Institutions

It didn’t come as a surprise to us when we saw the recent comments by the chair of the Committee of Public Accounts where it was stated that both RBS and Lloyds Banking Group “found it difficult to provide the Treasury with appropriate and robust data on their assets”.

We find that holders of assets are increasingly asking us to carry out selective data integrity checks, on a percentage of the assets they hold, in order that they can identify where the ‘gaps’ are before they consider selling all or part of the portfolio.

Being labelled ‘vendor due diligence’, these audit reviews often lead onto more significant investigations, due to the high error rates that we tend to find. Whilst we do not expect to find 100% accuracy in data, some of the mistakes we come across fall into a more serious category.

As an example, wrong interest rates being held on back office systems and therefore being incorrectly charged to borrowers, leaving the asset holder with the potential liability of breaching ‘Treating Customers Fairly’ (TCF) guidelines.

When such errors are discovered, we then undertake thorough reviews, often on the complete portfolio.

So, what can start as a ‘let’s verify the data we hold’ position, can end up uncovering more significant issues. As a result, we are increasingly helping clients to understand the wider issues, not least their TCF responsibilities.

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