FSCS Account Marking Process Modelling (BPM and DMN) March 2015

Transcription

1 FSCS Account Marking Process Modelling (BPM and DM) March 2015

2 Contents Page 3 Background 4 FSCS Account Marking Business Process Model (BPM) 5 FSCS Account Marking Decision Requirements Graph (DRG) 6 Decision Requirements Graph (DRG) Key 7-10 Account Marking Decision Tables 2

3 Background This pack shows a Business Process Model (BPM) to determine how accounts should be marked according to the recently recast EU Deposit Guarantee Scheme Directive (DGSD), and which deposits should be included on a Financial Services Compensation Scheme (FSCS) Single Customer View (SCV) file (other jurisdictions may implement SCV differently). Decision Model & otation (DM) is then used to specify how the decisions in this BPM are underpinned by a set of business rules and a network of dependencies. For an overview of impacts of the changes to the reporting process, please refer to the How Bank Work articles Impact of the Recast DGSD upon UK Banks Part 1 and Part 2, or the PRA s CP20/14 Paper. It is worth noting that the models here focus only on the DGSD requirement to mark accounts, and do not expand on the directive s other requirements. For more information on the benefits of using DM to feed data into the requirements definition process, please refer to the article on How Banks Work. For more information on any of the content of this pack or the associated article please contact us on info@trippleconsulting.co.uk. 3

4 FSCS Account Marking Process Model (BPM) Start (deposit record) deposit type? depositor? Mark as ineligible for FSCS protection geography? Should the a/c be on the Exclusions file? Is the depositor an SME/atural Person? Mark as large corporate, not geography Mark as SME/atural Person not geography Is the depositor an SME/atural Person? Is it a beneficiary a/c? Is the depositor an SME/atural Person? Mark as Large Corporate on SCV Mark as SME/atural Person on SCV Mark as a beneficiary a/c on Exclusions Mark as SME/atural Person on Exclusions Mark as Large Corporate on Exclusions Calculate how much compensatable balance a/c holds * * This box represents the next stage of the process in order to comply with the complete set of DGSD requirements. It is not modelled in these slides. 4

5 FSCS Account Marking Decision Requirements Graph (DRG) 1 How should the account be marked? Marking Rules 2 Is the depositor an SME/atural Person? SME Criteria 3 Should the a/c be on the Exclusions file? 4 depositor? Exclusions Rules 7 Is it a beneficiary a/c? Depositor Rules 5 deposit type? 6 geography? Beneficiary a/c definition Deposit-Type Rules Geography Rules CP 20/14* Account Data PRA *ote: The Knowledge Source for all the rules in this DRG is the PRA s Consultation Paper CP 20/14. 5

6 Decision Requirements Graph (DRG) Key Decision Business Knowledge Model Input Data Knowledge Source A decision denotes the act of determining an output from a number of inputs, using decision logic which may reference one or more business knowledge models. A business knowledge model denotes a function encapsulating business knowledge, e.g. as business rules, a decision table, or an analytic model. An input data element denotes information used as an input by one or more decisions. When enclosed within a knowledge model, it denotes the parameters to the knowledge model. A knowledge source denotes an authority for a business knowledge model or decision. Information requirement Knowledge requirement Authority requirement An information requirement denotes input data or a decision output being used as one of the inputs of a decision. A knowledge requirement denotes the invocation of a business knowledge model. An authority requirement denotes the dependence of a DRD element on a knowledge source, or the dependence of a knowledge source on input data. 6

7 1 How Should the Account be Marked? Marking Account Rules Eligible by Depositor? Eligible by Deposit- Type? Eligible by Geography? Conditions for Marking Reason to include on Exclusions File? Beneficiary Account? Is the Depositor an SME/atural Person? 1 O ES or O ES or O ES or O ES or O ES or O Mark as Ineligible for FSCS Protection 2 ES or O O ES or O ES or O ES or O ES or O Mark as Ineligible for FSCS Protection 3 ES ES O ES or O ES or O ES Mark as SME Ineligible only by Geography 4 ES ES O ES or O ES or O O Mark as Large Corporate In Geography 5 ES ES ES ES O ES Mark as SME/atural Person and Include on Exclusion File 6 ES ES ES ES O O Mark as Large Corporate and Include on Exclusions File 7 ES ES ES ES ES ES or O Mark as Beneficiary Account and Include on Exclusions File 8 ES ES ES O O ES Mark as SME/atural Person and Include on SCV 9 ES ES ES O O O Mark as Large Corporate and Include on SCV Outcome 2 Is the Depositor an SME/atural Person?* Is the Depositor an SME/atural Person? SME/atural Person Categorisation Rules Account Belonging to Turnover less than 50m Balance Sheet less than atural Person? annually? 43m annually? Less than 250 Employees? 1 ES ES or O ES or O ES or O atural Person 2 O ES ES es or O SME 3 O ES ES or O ES SME 4 O ES or O ES ES SME 5 O ES O O Large Corporate 6 O O ES O Large Corporate 7 O O O ES Large Corporate Outcome * The PRA have suggested conflicting definitions for an SME. This decision table is based on the definition which seems most plausible and is most consistent with the rest of the regulation but clarification from the PRA has been sought. 7

8 3 Should the Account be on the Exclusions File? Exclusions File Inclusion Rules Reason for Inclusion HMTS LEGDIS LEGDOR BE Outcome 1 O O O O Include on SCV 2 ES ES or O ES or O ES or O Include on exclusions (flagged HMTS) 3 O ES es or O ES or O Include on exclusions (flagged LEGDIS) 4 O O ES ES or O Include on exclusions (flagged LEGDOR) 5 O O O ES Include on exclusions (flagged BE) 8

9 4 Is the Account Eligible by Depositor? Eligibgle for FSCS Protection by Depositor Rules Is Deposit Deposited on Behalf of Credit Institution? Financial Institution? Investment Firm? Insurer? Public Authority? Credit Union? Outcome 1 O O O O O O Eligible Deposit 2 ES O O O O O ot Eligible Deposit 3 O ES O O O O ot Eligible Deposit 4 O O ES O O O ot Eligible Deposit 5 O O O ES O O ot Eligible Deposit 6 O O O O ES O ot Eligible Deposit 7 O O O O O es ot Eligible Deposit 5 Is the Account Eligible by Deposit-Type? Eligibgle for FSCS Protection by Deposit-Type Rules Collective Investment Undertakings Pensions and Retirement Funds Type of Deposit Laundered Money Unidentified Holder 'Own Funds' Outcome 1 O O O O O Eligible Deposit 2 ES O O O O ot Eligible Deposit 3 O ES O O O ot Eligible Deposit 4 O O ES O O ot Eligible Deposit 5 O O O ES O ot Eligible Deposit 6 O O O O ES ot Eligible Deposit 9

10 6 Is the Account Eligible by Geography? Eligible for FSCS Protection by Geography? Geography Rules Placed Inside EEA Placed Outside EEA Outcome 1 ES O Eligible Deposit 2 O ES ot Eligible Deposit 7 Is it a Beneficiary Account? Is the Account a Beneficiary Account? Beneficiary Account Rules Account Flagged as BE? Outcome 1 ES Benficiary Account 2 O ot Beneficiary Account 10