[TimSchumann]

This seems entirely reasonable, but you forgot the 0'th step.

Create a source of truth. I'd bet a 'source of truth' internal to the bank doesn't exist right now, and they're probably pulling something manually from an external 3rd party.

And on with the regress..

Step -1) What form will this internal source of truth take, how much will it cost, and who builds that system?

Step -2) Who gets to make that decision?

My uncle used to do this kind of work and man, he has some horror stories. The common thread among his clients seemed to be 'We know we need to do something, we know it will cost a lot of time and money, and it absolutely cannot fail.' The hard part always seemed to be finding the person within the org who had both the authority to spend the money, the political clout to make the decision. Nobody wants to own something like that going wrong. The actual technical part of the work, they had that down pretty well as it was all they did.

[Misdicorl]

That's table stakes as far as I'm concerned. If it can't be done quickly and correctly, you're in for a world of hurt. An organization in that position shouldn't be doing their own engineering. An individual in that situation should be brushing up their resume.

[mey]

It's amazing how hard the "system of record" conversation can be.