Data is in abundance these days. Companies are hungry for even the most mundane data points in a quest to glean insights to transform customer experience and product offerings. While many organisations are challenged with how to turn this data into usable insights, it’s clear that ASIC remains ready to welcome data with open arms.
True to their 2017-2020 data strategy, ASIC is preparing to receive large quantities of standardised, searchable data sets from regulated entities thanks to prescriptive requirements in impending legislation (e.g. RG 271’s complaints data pilot, reportable situation form supporting RG 78). Recent notices have also shifted away from ‘Please explain’ language to targeted data requests, further feeding ASIC’s ravenous data repository. In recent years there have been numerous examples of ASIC’s data-driven approach to information gathering leading to ASIC gleaning insights that may have taken some in the industry by surprise. Reverse mortgages, add on insurance sales, breach reporting and the labelling of cash funds to name a few.
Although ASIC’s full analytics capability is yet to be revealed, entities big and small are scrambling to configure existing systems or implement entirely new systems to produce all the different data requirements to achieve compliance and enhance their own capabilities. However, it may be time to take a step back and consider the following points on data.
All data provided to ASIC is fair game
In their data strategy, ASIC outlines that ‘Where regulated entities already provide substantial amounts of data to us and other regulators, we endeavour to make better use of this data.’ It’s of course too early to tell how enthusiastic ASIC will be with this. However, the intent may well be to use analytical tools across historic data to identify long-running trends, previously undetectable non-compliance, and to support extensive multi-year investigations. While there’s little that can be done about retracting any previously submitted data, this should act as a reflection point for future submissions. The ‘Just give them everything and they can work out what they need’ approach is a tempting, quick option but is certainly now (more than ever!) ill-advised. Likewise, the ‘inundate them with data’ approach should continue to be avoided.
Don’t be the last to know
It’s always a bad look when an outsider finds problems in a business, especially when the outsider is a regulator and the problem is non-compliance or conduct harmful to end customers. Without investing in analytics resources and capabilities that routinely interrogate and analyse data, businesses risk the possibility that the regulator will uncover an issue that the business itself has not, leading to the inevitable scramble to create an analysis to demonstrate why there is no issue or to demonstrate that it’s all under control. Ideally businesses will invest in the capability to be the first to detect any potential areas of non-compliance or harmful conduct and to self-correct. The data will be there thanks to the new requirements, but it won’t turn itself into information.
It’s not all about the numbers
Nothing beats the tangible, objective facts, particularly when it’s a number or percent. The eye seems to be drawn to them as an easy representation of an often-complex issue. Customers impacted, dollar value of loss, complaints per product. These are examples of actual requirements but providing or receiving this data alone does not ensure compliance with the form or spirit of regulations.
Looking at the requirements under the Design and Distribution Obligations (DDO) for example, issuers and distributors need to take ‘reasonable steps’ to help ensure that a product reaches the intended customer. Part of these reasonable steps include having appropriate processes and controls in place at the distribution stage. If you’re a product issuer this means understanding the systems and controls in place at the distributors that are selling your products (RG274.146). Data (complaints, significant dealings) might get you part of the way. But even if data does make it to you from all the parties in the distribution chain, and if you analyse it frequently and meaningfully, it still remains a lagging indicator of potential issues within the distribution chain and is no replacement for proactive and meaningful distributor monitoring.
There’s no doubt that data is the way of now. But it’s important to remember that data can have inherent limitations and is only useful when converted to information.
Candace@px.partners is an accountant by trade and at heart (really) and loves turning numbers into information. Talk to Candace, Tanushree@px.partners or Jon@px.partners about how PX Partners can help you with finding meaningful information in your business.