The Basel Committee has made bank self-assessments more thorough and precise, and banks have learned more about regulatory expectations and the size of their gaps—and the complexity, cost, and effort needed to close them.
Now is the time for banks to review the direction and pace of their BCBS 239 compliance efforts. If program changes need to be made, executives should be aware and act while time remains. This paper explains the issues, and shares the experience of compliance first movers. Many lessons merit consideration as deadlines loom across the sector.