As the situation of a financial conglomerate worsens, the nature and scope of the problems being encountered will influence the types of information supervisors will be interested in accessing. As such, specific types of information needs cannot be anticipated in advance and will need to be determined on a case-by-case basis. Supervisors' needs will only be met if the conglomerate has in place good information systems which will permit accurate and detailed information to be retrieved in a timely and reliable manner. In an emergency, supervisors' information needs will often be sharply focused and potentially very detailed. Supervisors may not seek the same types of information as set out below for any given emergency. While the primary information needs in an emergency will be firm-specific, there may also be a need for information relating to depositories, exchanges and clearing organisations. In order to respond to emergency situations in a timely and effective way, the information requirements of supervisors can be characterised as follows:
- Updates of information that should be on hand or readily available to supervisors;
- Information that supervisors will likely want to obtain during the course of an emergency;
- Information that will permit supervisors to assess the impact of an emergency on other financial firms under their supervision; and
- Information that provides the context of the emergency and its potential course.
In some unusual emergency circumstances, such as a major fraud or operational failure, the quality of some information from a supervised entity may be compromised. In such circumstances, supervisors will need to develop alternative sources of information or a strategy with which to obtain approximations of the financial and risk exposure information needed.
In an emergency, supervisors need to establish communication with a representative of their supervised entity (or entities) who can act as the contact person to provide requested information to the supervisors and to act as the primary liaison between the supervisors and the supervised entity. This person, which in unusual circumstances could be appointed from outside the supervised entity, should be designated as soon as possible once the emergency is detected.
The more familiar the supervisor is with the conglomerate's operations, the better positioned it will be to act in an emergency situation. Completing the Conglomerate Questionnaire and matrix in advance of an emergency can be a useful supervisory tool.
A. Information That Should Be On Hand or Readily Available to Supervisors
B. Information that Supervisors will likely want to obtain during the course of an emergency situation
C. Information That will Permit Supervisors To Assess the Impact of An Emergency On Other Financial Firms Under Their Supervision
D. Information That Relates to Actions That Could Influence the Course of the Emergency