Measuring and Managing Operational Risk

2 Assessing Operational Risk Exposure Required Process of Continuous Risk Assessment, Monitoring and Reporting

3 The Process Risk Identification Assessment of Control Framework Risk Likelihood/Severity Assessment Measurement & Monitoring Reporting Mitigation

4 The Tools Control and Risk Self Assessment Key Risk Drivers and Indicators Loss Data Issue and Event Data Audit and Compliance Reports Scenario Analysis

5 Control and Risk Self Assessment (CRSA) Utilises business management to identify risks and controls Comes in various forms –Scorecard Closed Questionnaire –Open ended Questionnaire –Business defined risks and controls Can be based on interviews or brain storming sessions

6 Risk Drivers and Indicators Drivers Transaction Volume Staff Turnover Market Volatility Training hours vs. plan Product complexity Indicators Transaction errors Aged confirmations Reconciliations Audit points outstanding Settlement fails Operational loss

7 Loss Data Pinpoints actual areas of control failures Highlights cost of operational risk Losses should be assigned to the business areas where they originated Data required for modelling Operational Risk Capital requirement. Both internal and external loss data can be utilised

8 Internal Loss Data Apply a minimum reporting threshold E.g. Losses > Eur20,000 Make sure you record at least the 4 W’s (What, when, where, why) Allocate losses to correct business line and risk category. Ensure that you can revise the individual losses to record recoveries Include all losses !

9 Loss Event Types Internal Fraud External Fraud Employment Practices & Workplace Safety Clients, Products & Business Practices Damage to Physical Assets Business Disruption & System Failures Execution, Delivery & Process Management

10 External Loss Data A number of sources. E.g. BBA Gold database, OpVantage. Tends to focus on large tail event losses Good source of data to fill gaps in own data if using an LDA to capital allocation Issues of applicability and scalability Often used for control failure comparison and scenario analysis

11 Key Risk Drivers & Indicators Much of the data is already available Must agree limits beyond which risk is considered unacceptable Must be indicators of risk not just of performance Should try to be predictive Ideally should be aligned to risks identified in CRSA and scenario analysis

12 Common Problems with Risk Indicators Performance related not risk related Where do you set the targets Inconsistent and non-comparable Historical not predictive One dimensional. Management takes it personally

13 Possible Solutions Adapt performance indicators to become risk indicators with their own specific targets. Targets should be ratified by senior management. Try to be consistent across business lines. Its easier to compare and aggregate Combine drivers and risks E.g. Outstanding reconciliations compared to volume and estimated staff turnover/absence. Present KRI’s as risk management tools not instruments of blame.

14 Issue and Event Data Not all control failures result in loss “Near miss” data adds value by verifying controls are working and that risks exist Control failure profits are as important as losses. Good source for potential fraud. Evidences adequate monitoring and control awareness

15 Audit and Compliance Reports Ideal source of control verification Independent review may highlight risks that have been overlooked or evaded Underscore efforts for risk mitigation Highlight topical risk areas Can provide valid control comparison

16 Scenario Analysis Apply some formal real world “what if” analysis to your processes Highlight control weakness before it results in losses Stress test identified points of failure to test resilience Test again to ensure mitigation is working

17 Problems and Practicalities Continued management support. Management deniability. KRI’s focussed on performance. Loss data collection and apportionment. Time and resource. External loss data applicability. Real world scenario analysis. Turning the data into a workable capital allocation model for AMA.

18 Applying Common Sense to Control The better the controls the less the chance of loss The level of controls need to be equivalent to the level of risk Controls need to be consistently applied and measured. All controls should be documented and staff should be aware of the controls applicable to their function. Failures need to be highlighted investigated and understood. Operational Risk losses need to be tracked to reflect the levels of risk in a particular product or process. Risk measurement is the first step to evidencing risk management

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