Review of FFIEC Call Report Modernization Cost Benefit
Analysis
March 21, 2003 Audit Report
No. 03-018
Federal Deposit
Insurance Corporation Office of Audits Office of Inspector
General Washington, D.C. 20434
DATE: March 21, 2003
TO: Steven O. App, Deputy to the Chairman and Chief Financial Officer;
and John F. Bovenzi, Deputy to the Chairman and Chief Operating Officer
FROM: Russell A. Rau [Electronically produced version; original signed by
Stephen M. Beard for Russell A. Rau], Assistant Inspector General for Audits
SUBJECT: Review of FFIEC Call Report Modernization Cost Benefit
Analysis (Audit Report No. 03-018)
At the request of Corporation senior managers, we reviewed the cost benefit
analysis (CBA) and assumptions supporting the draft request to the FDIC Board of
Directors for funding the Federal Financial Institutions Examination Council (FFIEC) Call Report Processing Central Data Repository, dated January 23, 2003.
(Note: The FFIEC includes representatives from the Board of Governors of the
Federal Reserve System (FRB), National Credit Union Administration (NCUA),
Office of the Comptroller of the Currency (OCC), Office of Thrift Supervision (OTS),
and FDIC.) The senior managers requested that we provide them with our analysis
prior to the scheduled February 11, 2003, FDIC Board of Directors meeting.
Our objective was to determine whether the cost information contained in the
CBA was supported and the assumptions made were reasonable. We reviewed the
methodology and supporting documentation used to prepare the CBA. The scope of
our review was limited to determining whether the FDIC had adequately supported
amounts presented in the business case and the underlying assumptions were
reasonable. We did not evaluate the viability or benefits of the alternatives
and options in the case. A detailed discussion of our scope and methodology is
included as Appendix II. The purpose of this report is to provide you with the
results of our review and the slides (Appendix I) we used to brief management on
February 7, 2003. (Note: We amended the briefing slides to include
technical corrections and clarifications.) We conducted our audit in accordance
with generally accepted government auditing standards during the period January
27, 2003 through February 14, 2003.
BACKGROUND
FFIEC Effort to Modernize the Call Report Process. In 1998 the FFIEC’s
Task Force on Reports initiated a Call Report modernization effort. An outgrowth
of this initiative was the interagency Call Modernization project launched in
2001. The Call Modernization project is a collaborative effort of the FDIC, FRB,
and OCC to improve the processes and systems used to collect, validate, store,
and distribute Call Report information. (Note: Every national bank, state member
bank, and insured state nonmember bank each calendar quarter is required to file
Consolidated Reports of Condition and Income (Call Report).) Institutions
regulated by the OTS and NCUA are not required to submit Call Reports to the
FDIC. Accordingly, the OTS and the NCUA were not included in this project.
The FFIEC Call Modernization Steering Committee also established a Cost
Working Group to collect and analyze the cost of the current Call Report
processes across the FDIC, FRB, OCC, and the reporting institutions. The FDIC in
turn has a subgroup called the Institution Data Management (IDM) project team
that performed the study for the FDIC. The study identified current (year 2002)
annual operating costs of $10.5 million for the three agencies. Of the
$10.5 million, the FDIC incurs $7.6 million, the FRB $2.4 million, and the
OCC $0.5 million.
In May 2002, the FFIEC authorized the FDIC to issue a request for proposal to
have a contractor design, implement, and host a new facility for Call Report and
other bank regulatory reporting data. Bidding closed in October 2002, and the
Call Modernization Steering Committee completed its analyses of the proposals in
January 2003. The Committee tentatively selected a proposal in the amount of $39
million, which included $14 million in system development costs and $25 million
for system operation and maintenance over a 10-year period. Additional funding
of $5 million was requested for future contingencies, for a total contract
budget of $44 million.
Two Alternatives Considered. The IDM project team prepared a CBA, dated
January 23, 2003. The CBA compared two alternatives on the basis of cost,
benefit, risk, and sensitivity. The alternatives presented were as follows:
- Alternative 1: Enhancing Existing Agency Systems – This alternative
anticipated doing select upgrades of existing FDIC and/or FRB systems to
meet minimum business requirements and operational needs for sustaining
current Call Report performance levels.
- Alternative 2: Central Data Repository (CDR) Hosted by a Third-Party
Vendor – This alternative includes implementation of an interagency CDR
that meets the business and technical requirements defined by the FFIEC and
is hosted and maintained by a private-sector vendor.
Alternative 1. The current Call Report process uses a 10-year old
distributed approach to obtain, validate, and distribute Call Report data.
Reporting institutions provide their Call Reports in electronic format to a
private vendor, Electronic Data Systems, that consolidates and distributes the
Call Reports to the FRB using the 25-year old Bulk Data Transfer format. The FRB
parses the consolidated data based on the primary regulator and distributes
FRB-supervised institutions’ data among the 12 Federal Reserve District Banks
and sends FDIC- and OCC-supervised institutions’ data to the FDIC. The FDIC
and the District Banks then edit the data using in-house methods and systems,
resolving exceptions based on a combination of common and agency-specific
criteria. Once the data are edited, files are exchanged among the regulators,
and a consolidated file of all reports is compiled and distributed to internal
and external customers.
Alternative 2. The Agencies developed a consensus vision for a new Call
Report processing business model that incorporates open data standards, uses a
common reporting language, and offers tools to enable banks to submit better
reports. The goals of the proposed environment are to create: (1) a single CDR
serving as the official source of all the information necessary for collecting,
validating, and distributing bank Call Report information; (2) a process driven
by uniform business rules leveraging existing standards; (3) a movement of
regulators and reporters to a recognizable Internet standard; (4) a common,
comprehensive set of FFIEC data quality assurance standards that will be defined
and published; and (5) a requirement that only Call Reports that pass all math
validation criteria and that provide text explanations for logical/qualitative
validation criteria exceptions will be accepted.
Alternative Chosen. The Call Modernization Steering Committee of the
FFIEC Task Force on Reports recommended alternative 2, with three actions
necessary to implement a CDR contract. The three actions included:
- Funding a contract to be awarded for an initial period of 7 years, with
three 1-year option periods, in the amount not to exceed $44 million for the
entire 10-year term;
- Entering into a Memorandum of Understanding governing the development and
operation of the facility, including business policy and oversight roles,
subject to concurrence by the FRB and the OCC; and
- Entering into an agreement for sharing costs of implementing and operating
the facility, subject to concurrence by the FRB and the OCC. The recommended
formula for cost sharing is 72 percent of the costs to the FDIC, 23 percent
to the FRB, and 5 percent to the OCC. (Note: The proposed cost-sharing
agreement is based on the current (year 2002) allocation of costs across the
Agencies as determined by the Call Modernization Steering Committee.)
RESULTS OF REVIEW
The methodology used in comparing the alternatives was generally consistent
with FDIC and Office of Management and Budget (OMB) guidance for the preparation
of cost benefit analyses. The IDM project team obtained and analyzed cost data
from several FDIC divisions, analyzed the benefits and risks associated with the
alternatives, and projected the impact that the cost benefit assumptions could
have on the recommended alternative in the sensitivity analysis. However, some
of the assumptions and rationale used to arrive at the amounts included in the
cost analysis were not consistently supported or clearly explained.
Specifically, formal management verification, indicating agreement with the
costs in the case, was not received from all affected divisions. As a result,
there is a risk that the return on investment may not be fully realized. In
addition, accountability for the cost benefits may be difficult to establish
because the assumptions made were not adequately documented. Nonetheless,
adjustments based on our concerns would fall within the range of the CBA
sensitivity analysis, which indicates a positive return on investment for the
CDR alternative chosen.
DETAILED RESULTS
Criteria
The
applicable criteria for our review were FDIC Circular 4310.1, Utilizing Cost
Benefit Analysis Methodology for the Purchase or Development of Capital Assets,
dated July 17, 1998, and OMB Circular No. A-94, Guidelines and Discount Rates
for Benefit-Cost Analysis of Federal Programs, both of which provide
guidance for preparing CBAs. (Note: Although OMB Circular No. A-94 does not
apply specifically to the FDIC, it is used as a prudent business practice in the
area of government cost benefit analysis.) According to the circulars, CBAs
should be performed to promote efficient resource allocation through
well-informed decision-making. The CBA is included as part of the
decision-making process when determining whether to purchase or develop a
capital asset. The analysis should be explicit about underlying assumptions used
to arrive at estimates of future benefits and costs. The analysis should include
a statement of the rationale behind the assumptions and a review of their
strengths and weaknesses. Key data and results should be reported to promote
independent analysis and review. In addition, post implementation verification
should be performed to determine whether anticipated benefits and costs have
been realized and whether improvements need to be made in future estimates of
benefits and costs.
The FDIC and OMB guidance recognize that there are inherent limitations in
the estimates of costs and benefits because of imprecision in both the
underlying data and the modeling assumptions. These limitations are generally
addressed in the sensitivity analysis where the risks associated with the cost
projections are addressed.
Cost Analysis
The Project Team’s Methodology for Preparing the Cost Analysis
In preparing the cost analysis, the IDM project team obtained cost data from
several divisions in the FDIC as well as the FRB and the OCC. In March 2002, the
IDM project team sent each FDIC division involved in the CBA a copy of the
current operating cost estimates for review. According to members of the IDM
project team, they did not receive any feedback from the divisions on their
March 2002 letter. The IDM project team did, however, obtain a subsequent
costing letter from the Division of Information Resources Management (DIRM)
regarding the DIRM costs included in the cost analysis.
Using this original cost data and a subsequent costing letter from DIRM, the
IDM project team prepared two cost alternatives. (Note: Each alternative had two
options. The first option related to core (Call Report) processes only, and the
second option was for value-added services including Uniform Bank Performance
Report processing, referred to as total or full implementation. Our analysis
relates only to the full implementation option because that was the
business-case-recommended option.) Alternative 1, Enhancing Existing Agency
Systems, was derived by using the current (year 2002) estimated operating costs
of the reporting processes and adding an additional $500,000 for the migration
of one of the systems to a new operating platform. Under Alternative 2, CDR, the
cost of current operations, which would no longer be necessary with the CDR, are
eliminated as CDR is phased into operations. Further, the cost of the CDR
contract is added to the cost of operations. The cost estimates were projected
over a 10-year period with a 3-percent annual inflation factor. Using these
amounts, alternative 2, CDR, results in a $27 million dollar reduction in costs
over the 10-year period. A discount factor of 5.1 percent was applied to the
cost reductions to arrive at a return on investment for the CDR of $17.9 million
(133 percent) over the 10-year period.
Our Analysis of the
Methodology
During our review, we attempted to verify the cost data and assumptions used
to derive the projections made in the cost analysis. Appendix II describes the
procedures we performed to evaluate the CBA. However, in certain instances the
data used or assumptions applied could not be traced to information included in
the CBA or to additional documentation obtained from the IDM project team. While
the DIRM costing letter was useful in validating the information included in the
cost analysis and supporting the reasonableness of the assumptions made, the IDM
project team did not obtain similar evaluations from the other divisions
impacted by the CBA. Also, the IDM project team did not prepare in advance a
methodology for ensuring consistent treatment of certain costs. If evaluations
had been obtained and cost assumptions defined, several of the cost concerns
discussed below may have been resolved.
Our Specific Concerns with
the Cost Analysis
- Alternative 2 did not clearly identify the staffing cost for the Call
Report process or project management. The cost analysis in the CBA
identifies a 50-percent reduction to the staffing requirements for the Call
Report process for alternative 2. No costs were identified in the cost
analysis for project management. However, according to the IDM project team,
project management costs for the CDR were in fact included in the Call
Report staffing cost for alternative 2. To more accurately reflect the cost
associated with alternative 2, project management costs should have been
clearly identified in the analysis, and there should have been a reduction
to the staffing requirements for the Call Report process. Although there was
no effect on the cost benefit, the source of the cost items was not clear
and made understanding the cost estimates difficult.
- Alternative 2 transition costs were not clearly defined or sufficiently
supported. Under alternative 2, the cost analysis identified legacy costs
from the current operations continuing in full through 2003. Beginning in
2004, only the UBPR legacy costs were included and no legacy costs after
2004. Legacy costs are the current costs not required after full CDR
implementation for a given phase. The analysis states that the projection of
legacy costs assumes functionality of the Call Report process as of year-end
2003 and full CDR functionality as of year end 2004. However, the project
plan included in the business case shows that CDR production will not begin
until mid-April 2004 with UBPR continuing for another year. This is
inconsistent with the legacy cost projections in the cost analysis. We
estimated that there will be $1.1 to $1.8 million more in legacy transition
costs based on the project implementation schedule included in the business
case, than is reflected in the cost analysis.
- Alternative 1 included an additional $500,000 to migrate the current Call
Report system to a new operating platform. This amount was in addition to
the IDM project team’s determination of the estimated annual cost
associated with system upgrades and enhancements. Our review of the
historical costs used for determining estimated future costs indicated that
system upgrades and enhancements were already included in the historical
projections. Accordingly, either this cost should not have been included in
alternative 1, or clarification should have been provided as to why this
cost was separate from the historical projections.
- Alternative 2 did not include the estimated cost of modifying the current
systems to accommodate data coming from the CDR. DIRM estimated a total cost
of $1.1 million to modify the current systems to accept data from the CDR.
DIRM noted that this was a transitional cost and would not be required if the
CDR was not approved. The members of the IDM project team stated that they did
not include this cost in the analysis because it was a "downstream"
cost and not specifically required of the CDR. As noted by DIRM, the exclusion
of this cost from the CBA required additional explanation. Including this cost
in alternative 2 would reduce the return on investment.
Benefit and Risk Analysis
As identified in the business case to the FDIC Board of Directors, the
assumptions related to benefits and risks are highly dependent on the vendor’s
successful implementation of the CDR. Because the CDR involves the use of new
technology, the risks are greater than those that would be expected with
existing proven technology both in terms of the success of the project and the
cost in implementing the project. As discussed in the case, the IDM project team
believes the potential benefits of the CDR project and new technology outweigh
the potential risks. Some benefits and risks were not quantified in dollar terms
in the CBA because the project team did not believe it was appropriate to do so,
given the uncertainty of their nature. The scope of our review did not include
an evaluation of these non-monetary benefits and risks. However, we did note
that the business case included a risk mitigation plan to address concerns
related to implementation of the new technology.
Sensitivity Analysis
A sensitivity analysis was prepared to determine how sensitive outcomes are
to changes in assumptions. The CBA identified the cost benefit of shutting down
current operations as CDR is implemented as the dominant assumption. The
sensitivity analysis projected the impact that a reduction in the cost benefit
would have on the return on investment over a 10-year period. In preparing the
sensitivity analysis, the IDM project team projected cost benefit reductions of
10, 25, 35, and 47 percent (47 percent represented the "break-even"
point). If the reduction in cost benefit exceeds 47 percent, then the investment
costs would not be recouped in full. The sensitivity analysis was performed
properly.
CONCLUSIONS AND SUGGESTIONS
The effect of the cost concerns discussed above would be a reduction in the
realizable ROI from $17.9 million (133 percent ROI) to about $14.6 million
(109 percent ROI). Consequently, even with the adjustments, alternative 2, CDR,
still provides the best-cost alternative given the other data included in the
cost analysis. The potential adjustments fall within the 10-percent reduction of
the sensitivity analysis included in the CBA. Based on the limited nature of our
review, we do not have a sufficient basis to make recommendations related to the
cost benefit analysis for the CDR or future investments. However, we suggest
that the FDIC consider:
- Ensuring that assumptions made in preparing a CBA are fully documented to
facilitate the post implementation review of benefits and costs, and
- Including a requirement in FDIC Circular 4310.1 that each division
impacted by alternatives in a CBA review concur or non-concur with its
contents to establish accountability. Any non-concurrence from an impacted
party should also be discussed in the CBA.
MANAGEMENT VIEWS
We discussed the results of our review and presented the attached slides to
officials from the IDM project team on February 7, 2003. The IDM project team
generally agreed that the assumptions and rationale used in preparing the cost
analysis could have been better supported and more clearly explained. In
consideration of the comments received from management, we amended the slides to
include technical corrections and clarifications. The CFO and COO agreed with
our suggestions and provided joint written comments to a draft of this report.
These comments are included as Appendix III.
In response to our suggestions, the Corporation will:
- Further emphasize in FDIC Circular 4310.1 the importance of fully
documenting cost and benefit assumptions in a manner which will facilitate
post implementation reviews, and
- Add a sample form for detailing cost and benefit assumptions by
division for each alternative, requiring concurrence by a senior
representative of each affected division.
APPENDIX I
SLIDES PRESENTED TO CDR PROJECT TEAM
AT FEBRUARY 7, 2003 BRIEFING
Call Report Modernization Cost Benefit Analysis
- On January 23, 2003, OIG was asked to evaluate the Cost Benefit Analysis (CBA)
- The objective was to determine whether (1) the information contained in the
CBA was supported and (2) the assumptions made were reasonable.
- Preliminary results needed before February 11, 2003, FDIC Board of Director’s
meeting.
Background
- The CBA presents two main cost proposals. The first proposal is for
enhancing current systems. The second proposal is for implementation of the
Central Data Repository (CDR).
CBA Contents
- Cost Analysis
- Benefit Analysis
- Risk Analysis
- Sensitivity Analysis
Criteria
- FDIC Circular 4310.1 Utilizing Cost Benefit Analysis Methodology for the
Purchase or Development of Capital Assets
- OMB Circular A-94 Guidelines and Discount Rates for Benefit-Cost Analysis
of Federal Programs
Cost Analysis
- Methodology for preparing the cost analysis is consistent with FDIC and OMB
guidance.
- Exhibits and supporting tables were generally computed accurately and
sufficiently explained.
- Inflation and discount factors were appropriate.
- Two main cost proposals: enhancing current systems (alternative 1) or
implementing the CDR (alternative 2).
- Cost projections are made over 10 years.
OIG Cost Analysis Concerns
- Some assumptions and rationale used to arrive at costs were not consistently
supported or clearly defined. Specifically:
- Project management costs for the CDR were not identified in the CBA.
- Additional system enhancement cost of $500,000 was added to historical
data for enhancements. The rationale for the additional cost was not fully
supported.
- Transition costs associated with the change to the CDR were not fully
factored into the CBA. These are costs that are expected to continue until
2005. The cost analysis shows these costs discontinuing earlier. OIG
estimates an additional $1.1 to $1.8 million in transition costs will be
incurred.
- A development project to modify current systems for the CDR
implementation, with an estimated cost of $1.1 million, was not included in
the cost analysis.
Benefit Analysis
- Both quantifiable and non-quantifiable benefits are addressed in the benefit
analysis.
- The only quantifiable benefit was based on the cost analysis.
- Non-quantifiable benefits of the CDR option are:
- Eliminate duplicative processes among FFIEC agencies.
- Direct transmission of Call Reports.
- Reject non-conforming reports before processing
- Update technology
- Benefits consistent with Business Case
- FDIC as an innovative leader in comprehensive banking information
- Delivering high-quality data faster
- Creating new value from current and future products
- Benefits to the industry
- Improving Agency operational effectiveness
Risk Analysis
- Presentation conforms with guidance from OMB for conducting the risk
analysis.
- Higher risk associated with CDR.
- Risk mitigation plans were identified for risk related to evolution of XBRL
standards, Regulatory Burden, Implementation Risk, and Funding Risk.
- Risks consistent with Business Case
- XBRL new technology
- Size of the expenditure
- Outsourcing the hosting and maintenance
- Operational Control
- Capturing the savings
OIG Benefit and Risk Analysis Comments
- The Business Assumptions Benefits and Risks are highly dependent on the
success of the new XBRL protocol for financial information reporting
- The case includes a risk mitigation plan to address anticipated issues
related to XBRL
Sensitivity Analysis
- Sensitivity analysis was performed properly.
- Sensitivity analysis identified the dominant benefit as the cost savings
resulting from the shutdown of Call Report and other reporting processes and
systems. The risk is that FDIC will not be able to shut down operations and
realize cost savings as CDR is implemented.
OIG Summary Conclusions
- The DIR generally followed the guidance of FDIC Circular 4310.1 and OMB
Circular A-94 in performing the Cost Benefit Analysis.
- "Estimates of benefits and costs are typically uncertain because of
imprecision in both underlying data and modeling assumptions." OMB
Circular A-94
- Adjustments based on OIG concerns are within the range addressed in the
sensitivity analysis.
- Cost Benefit Analysis process could be improved.
Objective, Scope, & Methodology
- Objective: To determine whether (1) the information contained in the
business case is supported and (2) the assumptions made are reasonable.
- Scope: FFIEC Call Report CDR business case dated January 23, 2002
- Methodology: Review the business case, supporting documentation, and FDIC
and OMB guidance for case preparation. Interview personnel involved in the
preparation of the case.
APPENDIX II
SCOPE AND METHODOLOGY
To accomplish our objective, we interviewed Headquarters Division of
Insurance and Research (DIR) officials who were responsible for the preparation
of the CBA. We also interviewed DIR, DIRM, and Division of Finance (DOF)
officials who were involved in the accumulation of FDIC cost data included in
the CBA. We reviewed key documents supporting the CBA, including spreadsheets
prepared by the IDM project team, cost assumptions prepared by DIRM, personnel
cost figures prepared by DOF, contract costs, and other documents related to
specific cost items.
The scope of our audit was limited to determining whether the FDIC had
adequately supported amounts presented in the business case and the underlying
assumptions were reasonable. Our audit did not evaluate the viability or
benefits of the alternatives and options in the case. We did not evaluate the
internal control environment over the preparation of the business case. We will
assess internal controls in future audits of the IDM project. In addition, our
audit did not assess the FDIC’s compliance with applicable laws and
regulations because we did not identify specific laws or regulations pertaining
to the development of the business case.
Our audit included a determination of whether the FDIC had incorporated
performance measures in the business case. We noted that the case describes its
alignment with the FDIC strategic vision, mission, and business goals by
promoting interagency collaboration, consolidating back office operations,
leveraging new technologies for current and future operations, and promoting the
FDIC as the source for banking data.
In addition, we relied on computer-processed data without performing tests of
system general and application controls to confirm the reliability of the data.
We verified that the computer-generated computations were accurate, but we did
not review the source data obtained from the systems. However, nothing came to
our attention as a result of specified audit procedures that caused us to doubt
the reliability of the computer-processed data. Throughout the audit, the
auditors were sensitive to the possibility of abuse or illegal acts.
We conducted our audit in accordance with generally accepted government
auditing standards during the period January 27, 2003 through February 14, 2003.
APPENDIX III
CORPORATION COMMENTS
Federal Deposit
Insurance Corporation Washington, DC 20429 Deputy to the Chairman
March 17, 2003
MEMORANDUM TO: Russell A. Rau, Assistant Inspector General for Audits
FROM: Steven O. App [Electronically produced version; original signed by
Steven O. App], Deputy to the Chairman and CFO; and John F. Bovenzi
[Electronically produced version; original signed by John F. Bovenzi], Deputy to
the Chairman and COO
SUBJECT: Review of FFIEC Call Modernization Cost Benefit Analysis
(Assignment No. 2003-026)
At the request of the Capital Investment Review Committee, the Office of
Inspector General (OIG) reviewed the cost benefit analysis (CBA) and the
assumptions supporting the draft request to the FDIC Board of Directors for
funding the Federal Financial Institutions Examination Council (FFIEC) Call
Report Processing Central Data Repository (CDR), dated January 23, 2003. The
objective was to determine whether the cost information contained in the CBA was
supported and whether the assumptions were reasonable.
The OIG reviewed the methodology and supporting documentation used to prepare
the CBA. Based upon the limited nature of the review, the OIG did not have a
sufficient basis to make recommendations related to the cost benefit analysis
for the CDR or future investments. However, the OIG provided suggestions for
improving the FDIC cost benefit analysis directive (FDIC Circular 4310.1).
We concur with and appreciate the OIG suggestions. We are currently in the
process of updating or replacing our cost benefit policy to include additional
elements such as return on investment (ROI). As part of this effort we will:
- Further emphasize in the directive the importance of fully documenting
cost and benefit assumptions in a manner which will facilitate post
implementation reviews, and
- Add a sample form for detailing cost and benefit assumptions by Division
for each alternative, requiring concurrence by a senior representative of
each affected division.
Overall, we believe the OIG review presented a fair evaluation of the work
performed by the CDR project team.
Cc: Vijay G. Deshpande Arthur Murton Fred Selby Michael MacDermott James
Collins James E. Crum Thomas Peddicord Gail L. Verley
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