Case Study

Regulatory Reporting Data Trace Program

In collaboration with one of the world’s largest international banking groups, Arrayo embarked on a crucial initiative – the Regulatory Reporting Data Trace Program. The program aimed to ensure that the data used for risk and regulatory reporting consistently adheres to rigorous quality standards, and aligns with the Basel principles for effective risk data aggregation and reporting. Arrayo’s objective was to gather evidence on data controls, quality, and operations to support the attestation of regulatory reporting.


Our client, an international banking group, operates across various business units, providing a full range of banking and financial services.

Before engaging with Arrayo, the client faced challenges in ensuring data accuracy and alignment with regulatory requirements for their risk and regulatory reports. They sought to strengthen their internal control framework and verify the effectiveness of their data operations. The absence of an organized data trace program hindered their ability to verify data accuracy, impacting their regulatory compliance.


To address the client’s challenges, Arrayo designed a robust Regulatory Reporting Data Trace Program, focusing on three key pillars:

  1. Risk Assessment: The program’s starting point involved a thorough risk assessment of regulatory reports and Material Data Record Management (MDRM). The Risk Assessment pillar served as the foundation for subsequent phases.
  2. Transaction Testing: Arrayo’s data-driven Transaction Testing pillar encompassed sampling and testing transactions to validate data accuracy for regulatory reporting. It involved tracing transactions back to source documents and ensuring proper capture and transformation of information.
  3. Report Compliance: The Report Compliance pillar, guided by Risk Assessment outcomes, verified that regulatory reports met reporting requirements and that data fed MDRM adequately.


Arrayo’s diligent efforts and expertise in regulatory reporting and data analytics led to significant outcomes for the Regulatory Reporting Data Trace Program. Key outcomes include:

  • Data Accuracy and Compliance: By defining and testing key data elements and transactions used for regulatory reporting, Arrayo ensured that the information captured by the system remained accurate and aligned with source/legal documentation. This improvement significantly enhanced data accuracy and compliance with regulatory requirements.
  • Successful Risk Assessment and Transaction Testing: Arrayo’s team of Regulatory Reporting Subject Matter Experts (SMEs) and Data Analysts played a pivotal role in executing Risk Assessment and Transaction Testing phases. The successful completion of these phases for high-risk reports, including FR Y-9C, FR Y-11/FR Y-11S, FR Y-9LP, FFIEC 002, FFIEC 002s, FR 2900, FFIEC 009/009a, FR Y-14A, FR Y-14Q, and FR 2052s (5G), demonstrated Arrayo’s proficiency in handling complex regulatory reporting challenges.
  • Efficient Report Compliance Testing: The comprehensive tests conducted during the program can now be leveraged by the Report Compliance Testing team. This streamlined approach ensures a more efficient and effective compliance verification process.

Throughout the Regulatory Reporting Data Trace Program, Arrayo gained valuable insights into the intricacies of regulatory reporting and data trace processes. Our experience in handling challenges, such as multiple data flows and aggressive timelines, has equipped us with refined methodologies and effective strategies for future engagements in regulatory reporting.

Arrayo’s partnership with the international banking group in implementing the Regulatory Reporting Data Trace Program exemplifies our commitment to data accuracy, compliance, and efficiency. By delivering successful risk assessment, transaction testing, and report compliance verification, we have helped our client achieve higher data quality and ensure adherence to regulatory requirements. Arrayo remains dedicated to leveraging our expertise to create positive impacts for our clients’ regulatory reporting and data management practices.

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