Project Overview
A UK tier-1 investment bank with £840B assets under management, 48 regulatory reporting obligations (FCA, PRA,...
Technology Stack
Compliance & Standards
The Challenge
A UK tier-1 investment bank with £840B assets under management, 48 regulatory reporting obligations (FCA, PRA, Bank of England, ESMA post-Brexit UK retention), and an estimated £28M annual cost of regulatory reporting (420 full-time equivalents) needed to modernise their regulatory reporting technology stack — replacing a combination of SAS reporting scripts, Excel-based reconciliations, and manual XML generation. FCA Supervisory Data Returns, PRA Returns (Corep/Finrep), BoE statistical reporting, EMIR (UK), MiFID II transaction reporting, CFTC (cross-border), and UK GDPR for employee and counterparty data were mandatory. Budget: £200,000.
Our Approach
Regulatory reporting data architecture
single source of truth (SSOT) for all regulatory submissions.
Trade data lake
trade booking systems → Kafka (real-time trade event stream) → S3 raw zone (immutable trade event log) → AWS Glue (regulatory ETL — trade data transformed to regulatory schema) → Redshift (regulatory data warehouse).
Trade data quality
Great Expectations (automated data quality tests — trade completeness, counterparty LEI validity, instrument ISIN validation) before regulatory ETL.
Audit trail
every regulatory submission has an immutable lineage (raw trade event → ETL transformation → regulatory field mapping → submission XML/JSON).
PRA requirement
regulatory data retained 7 years (S3 Intelligent-Tiering with 7-year lifecycle policy).
FCA Supervisory Data Returns
quarterly submissions via FCA RegData portal.
Key returns
FSA001 (capital adequacy), FSA002 (credit risk), FSA028 (liquidity — LCR).
Automation
Redshift (regulatory data warehouse) → dbt (risk-weighted asset calculation models) → XBRL generation (FCA RegData uses XBRL format — EBA taxonomy) → FCA RegData API submission.
XBRL validation
XBRL taxonomy validation before submission (FCA RegData rejects invalid XBRL — automated pre-submission validation).
Reconciliation
- total RWA reconciled against management accounts before submission (automated — any variance >
- 0.1% triggers manual review flag).
PRA parallel submission
same underlying data generates both FCA and PRA returns — single calculation, multiple submissions.
MiFID II UK Transaction Reporting via ARM
MiFID II UK (retained post-Brexit): investment firms must report all transactions in financial instruments to FCA via ARM.
Transaction report
- 65 mandatory fields (instrument ISIN, LEI, price, quantity, execution venue, execution time).
- DTCC GTR (Approved Reporting Mechanism): transaction report submission.
Automation
trade execution → Lambda (transaction report generator — 65 fields from trade data) → DTCC GTR API (T+1 deadline).
LEI validation
GLEIF API (Global LEI Foundation — validate all counterparty LEIs before submission).
ISIN validation
Bloomberg OpenFIGI API.
Rejection handling
DTCC GTR returns rejection codes — automated re-processing with corrected data.
Daily rejection rate target
- <
- 0.1% (current industry average: 1.8%).
Bank of England statistical returns
- IADB (Integrated ALCO Data Base), CDIS (Capital Data and Integration System).
- BoE BSS (Bankstats Submission System): bank statistics via BoE API.
- EMIR UK (retained): derivative trade reporting to DTCC UK repository (equity, credit, interest rate, FX derivatives — all must be reported).
EMIR fields
- UTI (Unique Trade Identifier), LEI, trade type, product identifier (CFI code), notional, maturity, collateral.
- Double-sided
EMIR reporting
both counterparties must report — for client trades, bank reports on behalf of client (delegated reporting).
EMIR reconciliation
counterparty breaks (discrepancies between bank and counterparty EMIR reports) managed via automated break detection and notification workflow.
The Results
FCA, PRA, and BoE compliance confirmed.
Platform live at 28 weeks, £184,000 — under budget. 48 regulatory obligations automated.
Annual cost reduction: £18.4M (£28M → £9.6M — 34% reduction, 420 FTE → 280 FTE through redeployment).
MiFID II transaction reporting rejection rate: 0.04% (industry benchmark: 1.8%).
EMIR counterparty breaks: 0.8% (industry benchmark: 3.2%).
XBRL validation: 100% first-submission acceptance.
Regulatory data lineage: 100% (every submission traceable to source trade).
PRA SREP review: zero regulatory capital add-on from data quality issues.
“£18.4M annual cost reduction. 420 FTE to 280 FTE through redeployment — not redundancy. MiFID rejection 0.04% versus 1.8% benchmark. EMIR breaks 0.8% versus 3.2% benchmark. Zero regulatory capital add-on from data quality. XBRL 100% first-submission. PRA SREP: data quality noted as a strength. ClickMasters built 48 regulatory obligations into a single, coherent data architecture. Most RegTech vendors solve one problem. ClickMasters solved all 48 simultaneously." — Chief Regulatory Officer, UK Tier-1 Investment Bank (name withheld)”
Project Details
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