Accounts and Exposures
I do not believe the system needs to be directed to send borrowers confidential information to the Funding Corp and they become the mechanism for reporting this information to FCA. This data is too sensitive to allow it to go through another party for dissemination. I would ask who is responsible for the data that could be hacked or divulged to outside sources? Is it the Funding Corp who has been directed by the System and FCA or is it the FCA who has established the regulation? There have been too many instances recently of information being divulged and the System does not need to create another source for access. Why can’t the FCA disseminate the reports it desires? Why does the FCA have to reestablish their authority to gather such information? The more hands and/or systems the information goes through only increases the likelihood of error, data mismanagement or breach of borrower information. This new Regulation also increases the cost to the Associations and District Banks when other cost are already escalating. I would also ask if the FCA has developed a forecast for the increase cost in dollars and in man hours.