To think of BCBS 239 as just another regulation is to misunderstand its end game. Solving the challenges it lays down requires a strategic approach. Risk data aggregation needs executive sponsorship for a start – after all executives will now be responsible for approving the risk data aggregation and risk reporting framework.
A strategic approach will require a holistic mapping out of the risk data universe and this will be no small challenge. Given the pressing deadline in January 2016 for BCBS 239, the focus needs to be on accessing data, not moving data.