Data Management
The challenge
Risk data has become the limiting factor for the Finance and Risk functions. Not because there isn't enough of it — there is usually too much — but because it is fragmented, poorly documented, and hard to reconcile with the regulator's expectations.
The BCBS 239 principles — adopted in 2013 but only really enforced very recently — set a demanding bar: risk data must be complete, accurate, sound, traceable, timely, accessible, and auditable. For most institutions, meeting these criteria is no longer optional: it has become a condition of authorization, a recurrent topic in ACPR engagements, and more broadly the foundation without which no serious risk framework can hold.
OMOTE Advisory supports financial institutions on the governance, organization, and quality of their risk data.
Our Approach
At OMOTE, data management is not an IT discipline. It is a risk discipline applied to data — and that changes everything.
We approach data management issues through the same lens that structures the rest of our advisory work: the goal is not to deploy a platform, but to build a framework that produces data that is reliable, traceable, and defensible before a supervisor. The challenge is less technological than organizational and methodological — which is why purely IT-driven approaches so often miss it.
Areas of focus
BCBS 239 and regulatory compliance
Gap analysis, remediation plan, governance framework setup, documentation of applied principles, ACPR audit preparation. Alignment with data protection requirements — GDPR, access management, classification, confidentiality of client and risk data.
Collection, preparation, transformation, storage, lineage, and archiving. Every step designed with auditability in mind.
Control rules, KPIs, monitoring frameworks, incident-remediation processes, and articulation with the operational risk function.
Data modeling, master data management (clients, instruments, curves, hierarchies). Integration with upstream systems (core banking, treasury, trading floor) and downstream systems (regulatory calculations, reporting, model validation, dashboards and interactive views). Alignment with the model function. Industrialization of calculation pipelines and deployment of risk models (MLOps).
RIALTO KERNEL and risk data
The architecture of RIALTO KERNEL is a direct embodiment of the BCBS 239 principles. Every calculation in the platform is traceable down to the line, recomputable at any reporting date, and fully auditable. For institutions looking to overcome the structural deficits of their risk-data framework, RIALTO offers a path to industrialization that is fully consistent with modern prudential expectations.