There is a hierarchy of tasks in any job and a simple binary function that determines what is at the very top of the list of things to do. In other words, there are the steps that contribute towards success, and then there are the essential steps which must be taken to achieve success and without which the project fails. For the moon landings, for example, a functioning rocket was essential – the flag painted on the side, while important to show the then USSR who was top dog in space, was not critical to the success of the operation.
While not wanting to compare SEC Reporting Modernization to the Apollo program, it has just the same characteristics, in that some steps are essential for completion. The most important? Successful data management, because data is the foundation ingredient and if it is not up to scratch the whole program falls at the first hurdle.
What’s the challenge with regard to successful data management for N-PORT? We’ve gone over this many times in our blogs and communications in the last year but it remains the same. Form N-PORT requires timely, accurate, complete and consistent data, and yet the sources for data are vast and varied, with different formats and delivery mechanisms (we reckon about 40% of the data for the new regulations comes from “new” sources where the information is not readily available). A recent survey vindicates our view, with about two-thirds of respondents reporting the main challenge for Reporting Modernization, was either getting the data right or getting the data right in the tight 30-day timeframe set by the SEC.
However, here is where you have to be careful. Some providers of those offering an N-PORT solution might be telling you that they can handle data management, but in many cases, that is just not true – often they cannot, any more than the folks painting the side of a Saturn V rocket could also fine tune the engines. It is a specialist activity that takes both specific technology and experience.
Luckily we have this in abundance – in fact, data management has been one of our core activities for more than a decade, and we have solved data problems for some of the largest fund managers globally. In this, we have covered all of the domains required for N-PORT, helped them deal with literally hundreds of feeds and data suppliers, all the time applying business rules to ensure, timeliness, completeness, consistency and integrity.
Do you really want to take the chance that in less than a year you will find that the single most important (and highest risk) part of SEC Reporting Modernization isn’t actually on offer from your solution provider?