APRA released the initial Implementation Plan for the new Data Collection Solution, which will replace its data collection system, Direct to APRA (D2A), with a modern, efficient, web-based solution. The plan provides all entities with an early view of the implementation approach to the roll-out of the new Data Collection Solution, which is expected to go live in March 2020. It also provides high-level guidance on the key project milestones and their expected timeframes.
The Implementation Plan informs reporting entities on the actions required now to prepare for the commencement of the new solution in early 2020. It also outlines the approach for managing the Data Collection Solution project risk, along with APRA’s future direction for data collections. The plan covers the key implementation components, including readiness, testing, training, and support. As some information is still unknown and some plans may change once more information becomes available, another version of this Implementation Plan is scheduled to be released in July 2019. In its Implementation Plan, APRA states that, although it will help entities to prepare for the change, entities need to start planning their transition to the new Data Collection Solution to ensure they continue to meet their reporting obligations. Readiness checklists will be provided to entities, which will specify required actions throughout the transition, including involvement in testing and training activities. Readiness activities will occur in the second half of 2019 and early 2020.
The new Data Collection Solution will not have a production parallel run with D2A. However, a test environment will be made available before go-live which will enable entities to test uploading data and to perform a range of functions. Should entities use third-party service providers or RegTech providers to assist in the submission of their returns, it will be the entity’s responsibility to liaise and confirm with their providers that they are well-prepared for go-live. A production parallel run is not possible due to the wide range of entity reporting due dates. As per APRA, the reporting entities will be expected to:
- Manage their own internal readiness for the new Data Collection Solution
- Ensure the relevant people within their entities are receiving new Data Collection Solution project communications from APRA
- Develop internal business cases for funding and establish project teams as required to enable their own readiness
- Participate in the testing process to ensure they are able submit returns prior to go-live
- Ensure all relevant users are set up with authentication credentials for testing and go-live
- Ensure all relevant users complete the provided training prior to go-live
- Provide feedback and raise any concerns throughout the implementation
- Submit all data, including re-submissions, through the new solution post go-live
Keywords: Asia Pacific, Banking, Insurance, Reporting, D2A, Data Collection Solution, APRA
Scott is a Director in the Regulatory and Accounting Solutions team responsible for providing accounting expertise across solutions, products, and services offered by Moody’s Analytics in the US. He has over 15 years of experience leading auditing, consulting and accounting policy initiatives for financial institutions.
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