Closing ECB audit findings and building a BCBS 239-ready governance framework inside a post-merger group.
A pan-European fleet management group, freshly merged into a Tier 1 banking parent, faced open ECB audit findings across data governance and its A-IRB return-to-compliance programme. Data stewardship was informal, KDE cataloguing was done in spreadsheets, and there was no unified view of data taxonomy across the merged entities. We embedded within the Enterprise Data Analytics function for three years. We established and chaired the Finance & Risk Data Committee — ten data stewards across five departments — and built the governance operating model from the ground up. Over 250 critical data elements were migrated and expanded in Collibra, each with full lineage, ownership, and data classification. A harmonised logical data model covering 75+ entities was designed to close the A-IRB data gaps identified by the ECB, and the sourcing strategy for work-out costs, concessions and write-offs was defined end to end. Five ECB audit obligations were closed. The DPD dataset from the acquired entity was integrated into the group risk engine, aligning 2M+ customer accounts and improving group delinquency accuracy by 30%. Data quality errors fell by 25% and taxonomy alignment between finance and risk improved by 40%.