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Monday, October 13, 2025
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Tackling the TRIM Challenge – How Banks Can Get their Data Management and Data Quality Processes up to Scratch

Martijn Groot, VP of Product Management, Asset Control

The Targeted Review of Internal Models (TRIM) is well underway and it is having a significant impact on banks across the eurozone. TRIM is an initiative of the European Central Bank (ECB), designed to assess whether the internal risk assessment models, used by banks supervised by the ECB, comply with regulatory requirements and whether their results are reliable and comparable.

As part of the programme, the ECB is engaged in a process of reviewing the banks’ models, providing them with ‘homework’ to improve their processes, and then returning to inspect again. In carrying this out, however, the ECB understands that protracted discussions with the banks about the finer points of their risk assessment models with be of little value if they can’t trust the data that is being fed into them.

This article looks at the stipulations of TRIM around data management and the needs for a data quality framework that encompasses a range of dimensions from completeness to timeliness, accuracy, consistency and traceability. It goes on to look at the requirements to audit data, for clear data lineage across traditional ‘data quality silos’ and discusses the kinds of market data metrics that banks will need to report on. The article also discusses some of the overlap with some of the sought-for capabilities with global initiatives such as the new trading book regulation. Finally, it analyses the challenges banks face in achieving all this, and considers business processes and technology-related solutions they could employ to overcome these obstacles and meet the TRIM guidelines.

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