The accounting tie-in to risk reporting in BCBS 239
There is a ninth item in BCBS 239 that is as important if not more important than the eight items mentioned. BCBS has set a high water mark for the quality of risk data. It is to be as controlled as is the data entered into the books and records of the firm. From BCBS 239:
"Controls surrounding risk data should be as robust as those applicable to accounting data."
"Risk data should be reconciled with bank's sources, including accounting data where appropriate, to ensure that the risk data is accurate."
Supervisors expect banks to consider accuracy requirements analogous to accounting materiality.
BCBS 239 is truly a paradigm shift in risk management thinking.