"Significant Challenges" in Aggregating Data for Single Customer View Requirements

The single customer view requirements in the UK may initially appear to be straightforward, but it can be challenging to pull the around 10 reference data items together to become compliant, officials tell Inside Reference Data.

Around 800 deposit-holding institutions are required to create and maintain a single customer view (SCV) of each client under the Financial Services Compensation Scheme (FSCS) reform in the UK when it becomes effective in January 2011.

“There are some significant challenges in aggregating the data into the [required] format from across multiple systems,” says Colin Rickard, managing director EMEA, DataFlux.

The proposed reference data items required are: account-holder identifier, account-holder name, mailing address, email address, contact telephone numbers, account title, account number, product type, joint account-holder identifier and account status.

Even the account status, which will have to be identified as active, open, closed or dormant, is seen to potentially be difficult to implement. Rickard says if this standard is not in the system already, firms will have to run several business rules to assign a status.

London-based PJ Di Giammarino, CEO, JWG, says firms keep “stumbling across new complexities.” FSCS requires firms to use a unique identifier, but as there is no standard identifier, the identifier can vary from file to file. “In the absence of an identifier we can only compare the records,” he says, adding that this is “all a big puzzle.”

The reference information will also have to be combined with the balance information, meaning there needs to be a link to live data in the transactional systems. “Firms are trying to work out how to keep systems live and aggregate it in a way FSCS wants,” says Di Giammarino, explaining that part of the complexity is to identify the current balance, as there could be a number of different balances depending on weekend closures and when the transactions are reconciled, for example.

Single Record

Requirements for maintaining a single record of each customer are starting to become a common theme in regulatory directives, particularly as part of compensation scheme reforms aimed at ensuring customers can get their money back quickly in the event of a deposit-holding institution failing.

Yet, despite the range of new regulation relating to management of customer data, only 14% of firms see projects aimed at complying with SCV requirements in the UK as strategic opportunities, according to a survey by JWG, commissioned by DataFlux.

In fact, 50% of survey respondents said their firms started working on the project this year, and the majority have chosen to take a tactical approach. Fifty-seven percent are running an implementation strategy based on getting the basic capability to comply, and 29% are just trying to be compliant. “Sadly, there’s a common theme that the implementation window gets squeezed, and it is difficult for banks to use it in the best possible way,” says Di Giammarino.

The firms that did take a strategic approach said they started the project as early as 2007 and indicated they were dealing with complex infrastructures. “I don’t blame the people who were waiting to see if they had to deal with it, but the ones that took the long view had other business drivers as well,” he says.

Still, there are also many professionals who are unaware of the SCV requirements, and only 59% of people contacted for the survey, who were responsible for the data in their company, had heard about it. “This may well reflect the wealth of things they have to do,” says Rickard, adding that it has to be open for debate whether organizations will meet the January deadline. “There must be a feeling of regulatory overload,” he says.