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CFO Attestation Overview
Much of the Federal Reserve’s Comprehensive Capital Adequacy & Review (CCAR) is about demonstrating control, and this is particularly evident in the framework’s core CFO Attestation requirement. This framework introduces a formalized requirement to validate information, implement process controls and provide disclosures. The mandate requires the largest financial institutions to sign off on CCAR-related data accuracy, detail their auditing and escalation processes, and describe other mechanisms scrutinized under the regulation. While most firms already have certain aspects of this process formalized on an institutional level—to complete CCAR reconciliation, primarily—CFOs and their offices require a tailored monitoring layer, which in turn demands fresh innovation from their data management platforms.
AxiomSL’s robust and auditable environment, in line with the CFO attestation principles, provides the controlled framework around data collection, reporting and sign-off. This flexible platform enables CFOs to navigate through data on a granular level and develop their own workflows to reflect the individual institution’s process in a permissioned environment. Combined with the dashboard technology, AxiomSL has the tools needed to provide a holistic CFO attestation solution.
Reconciliation is a central task required by the Federal Reserve’s Comprehensive Capital Adequacy & Review (CCAR). For large and diversified institutions currently covered under CCAR, reconciling information across hundreds of touchpoints can become an onerous process and operational headache without a robust and agile platform. But beyond the traditional matter of ensuring consistency of reportable data, AxiomSL also views effective CCAR reconciliation in an additional way: as a matter of generating meaningful business insights, in addition to simply lining the data up.
AxiomSL’s platform provides a flexible, modular approach to tackling the various aspects of attestation and risk data governance with an integrated workbench for CCAR reconciliation. In fact, AxiomSL’s approach provides detailed reconciliation reports and business rules for analyzing comparable and reconcilable report schedules at the line item level with drilldown to the original source. For example, within the platform are the FR Y-14 vs. FR Y-9C reconciliation reports that work together to allow firms to attest that the FR Y-14A/Q/M, FR Y-9C and any reconcilable reports conform to Fed instructions along with the ability to identify and analyze material errors in data and reporting.
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