There is nothing outrageous or unrealistic about the 14 “Principles for Effective Risk Data Aggregation and Risk Reporting,” as spelled out in the Basel Committee on Banking Supervision’s 2013 document BCBS 239. It is plain common sense that risk reports should be validated, tied to a bank’s official accounting books and records, derived from single authoritative sources and be available in a timely manner. And yet a November 2014 white paper from SunGard, as reported in “The Bill for BCBS 239,” speaks of aggregate costs of $8 billion for the industry to achieve compliance and puts us on notice that we will be confronted by “a complex program of change.”

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