Continuity Of Regulatory Reporting Through Bank Resolution, Acquisition, And Entity Restructuring: Data Migration, Control Re-Establishment, And Supervisory Communication

Abstract

When a bank changes hands or changes shape, its regulatory reporting obligations do not pause. Required submissions continue on their established cadence while data, source systems, legal-entity hierarchies, controls, ownership and approval structures are simultaneously transferred or redesigned. The institution must determine which entity reports each balance, preserve historical comparability, prevent both omission and double counting, re-establish controls that the transition has invalidated, and confirm who is authorized to approve each filing. This paper documents an execution methodology for maintaining that continuity, drawn from thirteen years of regulatory reporting technology practice across three classes of transition: foundational capital-planning implementation, legal-entity creation and branch-to-subsidiary conversion, and post-acquisition integration under concurrent supervisory remediation. Four components are described. Data migration is treated as the preservation of reporting logic rather than the transfer of balances, on the argument that the fragile elements are not the balances but the contextual artifacts surrounding them: historical mappings, manual adjustments, undocumented transformation logic and definitions held locally or only by individuals. Control re-establishment is presented as a fourteen-step sequence in which a control is not restored when it runs again but when its execution can be evidenced and signed for. Legal-entity remapping is analysed through its hardest case, in which one exposure is simultaneously live in a legacy feed and migrated into a consolidated target, where including both feeds double counts and retiring the legacy feed early omits. Supervisory communication is treated as an evidence-production discipline rather than correspondence. The contribution is methodological. The paper reports no measurements, proposes a structured framework and an accompanying analytical model of the dual-feed overlap problem, and states its limitations directly.