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Operational Risk Management (ORM) Framework in Banks and Financial Institutions

Roadmap to Advanced Measurement Approach (AMA) and better business performance

Alan Greenspan, Chairman of the Federal Reserve American Bankers Association, during Annual Convention on October 5, 2004 held, “It would be a mistake to conclude that the only way to succeed in banking is through ever-greater size and diversity. Indeed, better risk management may be the only truly necessary element of success in banking.”

Banks and financial institutions are undergoing a sea change and today face an environment marked by growing consolidation, rising customer expectations, increasing regulatory quirements, proliferating financial engineering, uprising technological innovation and mounting competition. This has increased the probability of failure or mistakes from the operations point of view – resulting in increased focus on managing operational risks.

Operational risk losses have often led to the downfall of financial institutions, with more than 100 reported losses exceeding US$100 million in the recent years. The regulators of financial companies and banks are demanding a far greater level of insight and awareness by directors about the risks they manage, and the effectiveness of the controls they have in place to reduce or mitigate these risks. Further, compliance regulations, like Basel II and SOX, mandate a focus on operational risks, forcing financial organizations to identify, measure, evaluate, control and manage this ubiquitous risk. This has led to an increased emphasis on the importance of having a sound operational risk management (ORM) practice in place, especially when dealing with internal capital assessment and allocation process. This makes ORM one of the most complex and fastest growing risk disciplines in financial institutions.

Basel II and Operational Risk
Operational risk is as old as the banking industry itself and yet the industry has only recently arrived at a definition of what it is. Operational risk is defined by the Basel Committee on Banking Supervision (2006) as: “the risk of loss resulting from inadequate or failed internal processes, people and systems or from external events. This definition includes legal risk but excludes strategic and reputational risk”

Operational Risk: Changing Face of Compliance

Old perceptions and behaviors towards risk are changing. ORM is acquiring new credibility as a roadmap to add value to the business; and is garnering new attention from regulators and key stakeholders.

A recent Chartis Research's1 report on ORM systems, suggests that the worldwide financial services ORM market will continue to grow, reaching a total value of $1.55 billion by 2011. This indicates a growing concern among banks and financial institutions for managing their operational risk. The report has three main findings:

  • Many US and European financial institutions continue to replace their first generation ORM systems - largely due to inflexible and rigid product design and the ongoing evolvement of ORM methodologies.
  • Some market segments, such as emerging regions (e.g. Middle-East, Asia-Pacific, South America), and vertical sectors (e.g. insurance, asset management) have begun investing in formal and sophicticated ORM systems.
  • Average investment in ORM projects is increasing, as more and more financial institutions are focusing on ORM's strategic business benefits
  • Additionally, the report claims financial institutions working on the demand side of the market are reexamining their approach, culture and systems for managing operational risk.

There are two main drivers for this development. Firstly, there is a growing acknowledgement from banks that a consistent and effective operational risk management framework can help them achieve organizational objectives and superior performance. For example, by including a well-constructed operational risk process in the entire value chain, a bank can help ensure that the risks inherent in those activities are understood and addressed. In many instances an early involvement of operational risk management can increase the development speed of new initiatives.

The second key development is the launch of the Basel II Capital Accord (the New Accord) by the Basel Committee for Banking Supervision, which requires banks to set aside regulatory capital for operational riskan important development that has affected most financial services institutions worldwide. One of the major improvements in Basel II is that it ensures closer linkages between capital requirements and the ways banks mange their actual risk. As summed up by a U.S. regulator, “The advanced approaches of Basel II represent a sea change in how banks determine their minimum level of required capital for regulatory purposes. It intends to better align regulatory capital with inherent risks and banks' internal economic capital”

The advanced approach for measurement of operational risk requires economic capital to be calculated on the basis of bank’s own operational risk management & measurement technique. It is imperative to strengthen the soundness and stability of operational risk management practice by employing Advanced Measurement Approach (AMA); in order to ensure that it does not become a significant source of competitive inequity over rival banks & financial institutes. Further, AMA fosters risk sensitive environment and promotes efficiency in managing risk. The road ahead should lead to “Advanced Measurement Approach” (AMA) as described under Basel II accord.

Risk Sensitivity vs Capital Charge

An Ernst and Young's Global Basel Survey in 2006 indicates that senior banking executives are beginning to appreciate the long term business impacts of Basel II on their organizations and banking industry as a whole. It suggests a realization that Basel II adoption is a growing imperative in order to succeed in the competitive race. About 89% of the participants in the survey believed that the banks with robust risk infrastructures will have competitive advantage over others.

Source: Ernst & Young

To comply with the accord, banks are making significant investments to improve their internal risk processes, data infrastructure and analytical capabilities. Firms focused on competing effectively are already incorporating many elements of the Basel II requirements into their risk and capital management practices, as a blueprint fo improved growth and profitability.

As a result, Basel II compliance programs offer a rare opportunity to rethink the way banks approach risk measurement and managementz and to look again at how risk measures can be integrated with each other and with management’s approach to running the business. Susan Schmidt Bies2, one of the U.S. regulators, stressed, “The emphasis in the new Accord on improved data standards should not be interpreted solely as a requirement to determine regulatory capital standards, but rather as a foundation for risk management practices that will strengthen the value of the banking franchise.”

Although Basel II compliance opens up many strategic opportunities to leverage improved data standards and risk management practices, it also offers many implementation challenges. The next section highlights the major challenges in successfully implementing ORM.

Challenges of Managing Operational Risk

The discipline of operational risk is at a crossroads. Despite the industry's efforts to control operational risk, institutions still have much work to do. Risk Managers are grappling with questions like, ‘How does the discipline add value to my organization?’; ‘What does the advanced measurement approach’s (AMA) modeling techniques say about the operational risks my firm is facing?’; ‘What is the strategic role of operational risk my firm should adopt?’. Let’s take a look at some of the unique challenges that ORM brings:

  • Rising Costs of Compliance: Development of an ORM model as part of a regulatory and economic capital framework is complex and takes time. There is a general agreement that the major ORM challenge is escalating cost of compliance.
  • Access to Appropriate Information and Reporting: Effective management of operational risk requires diverse information from a variety of sources-including, for example, risk reports, risk and control profiles, operational risk incidents, key risk indicators, risk heat maps, and rules and definitions for regulatory capital and economic capital reporting.
  • Development of Loss Databases: A well-structured operational risk framework requires development of business-line databases to capture loss events attributable to various categories of operational risk. Basel II specifically requires a minimum of three years of data for initial implementation and ultimately five years for the Advanced Measurement Approaches (AMA). The need for historical data (including external data) has been a cause for concern for many enterprises.
  • Lack of Systematic Measurement of Operational Risk: Many enterprises hold that their institutions are measuring operational risk. However, very few of them have been able to complete the Basel II quantification requirements, or yet to formalize the measurement process around the Basel II framework.
  • Implementing ORM Systems: Amid regulatory efforts to re-vamp the industry’s immunity to operational risk, and its implications on efficient financial intermediation, many organizations are looking to go beyond traditional siloed approaches and implement a consolidated ORM framework across entire value chain. Development of an ORM model as part of a regulatory and economic capital framework, however, is complex and takes time. Some banks may either still be struggling with the requirements of the "Sound Practices for ORM" BIS paper, which spells out how to introduce ORM principles, or may not yet have in place the required governance or framework. Factors like lack of understanding of upcoming technology regarding operational risk management, failure to get the top management to focus on the benefits of the program, improved productivity and quality, as well as on loss reduction, and lack of meaningful and timely data across business unit and product lines make the implementation of an ORM system all the more formidable.
  • Tone at the Top: Effective risk management program starts with “The Tone at the Top”- driven by the top management and adhered by the bottom line. However, if bank’s top leaders perceive operational risk management solely as a regulatory mandate, rather than as an important means of enhancing competitiveness and performance, they may tend to be less supportive of such efforts. Management and the board must understand the importance of operational risk, demonstrate their support for its management, and designate an appropriate managing entity and framework - one that is part of the bank’s overall corporate governance framework.

 

By adopting an integrated operational risk framework, companies can ensure that all operational risks management initiatives are sustained and are aligned with the corporate strategy. Next section throws light on essentials of an ideal operational risk framework.

Risk Management Cycle

Building an Operational Risk Framework
Operational risk management is at the core of a bank's operations - integrating risk management practices into processes, systems and culture. As a pro-active partner to senior management, ORM's value lies in supporting and challenging them to align the business control environment with the bank's strategy by measuring and mitigating risk exposure, contributing to optimal return for stakeholders. For instance, HSBC3 has invested heavily in understanding customer behavior through new systems initially designed for fraud detection, which is now being leveraged beyond compliance to address more effective customer service.

The ORM group of an organization keeps its people up-to-date on problems that have happened to other financial institutions, allowing it to take a more proactive approach. "Our goal is for employees to look at ORM as a business stakeholder and a shareholder, involving them on all levels and bring stability into their jobs," said senior vice president of Operational and Compliance Risk Management Group. A noted financial services company, on the other hand, incorporates its ORM approach as an extension of its business line and not a separate entity. The company has implemented an operational risk umbrella that encompasses all aspects of potential risks - bank protection, fraud prevention, key risk indicators, capture of operational loss data, business line risk oversight and new products and initiatives for data security. Its Chief Risk officer quotes, "We utilize our ORM practices to gain respect and appreciation of all our business lines by really understanding their issues, and being part of the overall solution."

What elements should a financial institution consider when developing an analytical framework for operational risk?
There is no ‘one-size-fits-all’ approach to ORM – as every enterprise follows a framework that is specific to its own internal operating environment. When inquired about the standard ORM framework, a risk expert notes, “There is no "standard" standard. Ultimately, the Operational risk framework should not merely be Basel-compliant; it should also provide the bank with mechanisms for improving overall risk culture and behavior towards operational risk management. Understanding our risks should lead to better decision making and refelect in our performance”. A robust operational risk management framework is made up of the following core components:

An award winning Banking Group states that it is focused on the regular monitoring of its operational risk profiles and material exposures to operational losses- with senior
management supporting the proactive management of operational risks. Its Operational Risk Management department (“ORM”)

Carries out risk-audit activities, assessments of operational risks and prepares recommendations for risk mitigation.

Implements a number of tools recommended by the Basel Committee including: internal loss collection and reporting, key risk indicators, external loss data collection; and control and risk self-assessments.

Analyzes new products and intrabank regulations.

Holds comprehensive insurance policy, which is designed with ORM participation.

The group has received the Operational Risk Achievement Award for two consecutive years.

  • Governance: It is the process by which the Board of Directors defines key objectives for the bank and oversees progress towards achieving those objectives. It defines overall operational risk culture in organization, and sets the tone as to how a bank implements and executes its operational risk management strategy. A successfully executed risk strategy often results in risk being firmly embedded in the vision, strategies, tools, and tactics of the organization. Governance sets the precedence for Strategy, Structure and Execution.
  • Strategy: A bank’s strategy for operational risk drives the other components within the management framework and provides clear guidance on risk appetite or tolerance, policies, and processes for day-today risk management.
  • Appetite and Policy: An ideal risk management process ensures that organizational behavior is driven by its risk appetite. Adopting an operational risk strategy aligned to risk appetite, leads to informed business and investment decisions.
  • Clear Definition & Communication of Policy: An organization’s top management must identify, assess, decide, implement, audit and supervise their strategic risks. There should be a strategic policy at the board level to focus on managing risk all levels and conscious efforts should be made to ensure that these policies are communicated at all levels and across entire value chain.
  • Periodic Evaluations Based on Internal & External Changes: An ideal risk management process puts improvement of risk performance on a competitive level with other important mission concerns – periodically evaluating the ORM performance goals in the light of internal and external factors. Depending upon the criticality of internal operating environment and key external factors, organization must review the strategic policies inside out.
Operational Risk Management (ORM) Framework
  • Structure: When designing the operational risk management structure, the bank's overall risk scenario should serve as a guideline. This includes initiatives like laying down a hierarchical structure that leverages current risk processes, developing risk measurement models to assess regulatory and economic capital,and allocating economic capital vis--vis the actual risk confronted. Centralized aggregation of operational risk information collected via various self assessments across the organization, further, provides useful insight for the desired hierarchial structure. The implementation of these concepts allows risk to be handled consistently throughout the organization.
  • Execution: Once operational risk management structure have been established by an organization adequate procedures should be designed and implemented to ensure execution of and compliance with these policies at business line level. The first step includes identification and assessment of operational risk inherent in day-to-day processes of the bank. After assessment of inherent risk, target tolerance limit of risk should be established. This is commonly accomplished by calculating the probability/ likelihood of materialization of risk, by considering the drivers or causes of the risk together with the assessment of its impact. The results of the risk assessment and quantification process enables management to compare the risks with its operational risk strategy and policies, identify those risk exposures that are unacceptable to the institution or are outside the institution's risk appetite, and select and prioritise appropriate mechanisms for mitigation.

Finally appropriate risk mitigation and internal controls procedures are established by the business units such that residual risk is mitigated to the acceptable level. Regular reviews must be carried out, to analyse the control environment and test the effectiveness of implemented controls, thereby ensuring business operations are conducted within acceptable risk limits. Further, it is essential that the top management ensures consistent monitoring and controlling of operational risk, and that risk information is received by the appropriate people, on a timely basis, in a form and format that will aid in the monitoring and control. Operational risk metrics or “Key Risk Indicators” (KRIs) are established to ensure timely warning is received prior to the occurance of an event. Key to effective KRIs lies in setting threshold at the acceptable level of risk. Execution and implementation of Operational Risk framework is key to setting up effective Operational Risk environment ensuring that business is conducted within appropriate risk tolerance limit.

Business Benefits: Moving Beyond Compliance
As ORM efforts mature, and gain both the support and the confidence of management, they are becoming increasingly valuable to the business. Perceived initially to support regulatory requirements, these efforts can be leveraged and aligned with business performance management. To be successful, however, such alignment must be based on a clear vision of the potential benefits. Few of the benefits are discussed below:

  • Identified and assessed key operational risk exposures: ORM enables an organization to identify measure, monitor and control its inherent risk exposures of the business at all levels. Elements like Risk Assessment, Event Management, and Key Risk Indicator play an important role; enabling the organization to evaluate the risk controls, based on the identified inherent risk, and to measure the residual risk which remains after the implementation of controls.
  • Clarified personal accountabilities, roles and responsibilities for managing operational risks: Clear cut specification of roles and responsibilities of personnel regarding risk profile is an imperative part of implementing an integrated ORM framework. It not only streamlines the risk management process, but also allows risk managers to better incorporate accountability into the work culture of the organization.
  • Evolved and enabled efficient allocation of operational risk capital: With streamlined risk management process, efficient allocation and utilization of operational risk capital can be ensured.
  • Consistent and timely operational risk management information and reporting capabilities: Through the development of a well-tailored risk management strategy, a robust ORM system supports features like role-based dashboards, control diagrams and scorecards that provide visibility into the ongoing risk management efforts and bring high-risk areas into focus.
  • Sustained risk-smart workforce and environment: Application of an ORM framework, in conjunction with related risk management activities, will support a cultural shift to a risk-smart workforce and environment in the organization. An essential element of a risk-smart environment is that it ensures that the organization has the capacity and tools to be innovative while recognizing and respecting the need to be prudent in protecting its interest.
  • Ensured continuous risk management learning: Most business units today acknowledge that continuous learning is fundamental to more informed and proactive decision-making; and a successful learning organization must align itself to the businesses it supports. To ensure continuous risk management learning, these business units are sharing their experience and best risk management practices - internally and across organizations. This supports innovation, capacity building and continuous improvement, and fosters an environment that motivates people to learn.

However, successfully navigating the road from compliance to value creation can be daunting without a roadmap and a clear vision. By taking a holistic approach to ORM an organization can significantly lower its risk profile and improve responsiveness to risk scenarios leading to strategic and operational benefits.

MetricStream Solution for ORM

MetricStream offers industry’s most advanced and comprehensive solution designed to meet Operational Risk needs of banks & financial services. The solution is based on an integrated Enterprise Compliance Platform (ECP) for successfully managing risk and meeting regulatory requirments while lowering the associated costs that can otherwise be substantial. ECP, a proven infrastructure for building risk and compliance application, provides core modules and services to automate and streamline Opertaional Risk processes.

Chart representing operational failure

Its embedded best practices Expected loss is the amount a business should budget to cover its annual cost of operational failure while unexpected loss is the amount the business ought to reserve as capital.

MetricStream uniquely combines software and content to deliver ORM solutions content helps define the scope of processes and sub-processes for which risk management needs to be performed and guides development of control and test libraries. It brings together all risk management related data - a reusable library of risks and their corresponding controls and assessments, results from individual assessments, key risk indicators, events such as losses and near-misses, issues and remediation plans - in a single solution. It also provides other intelligent and content driven features such access to training content from an expert community from within the solutions and integration of business processes with regulatory notifications and industry alerts. Key components of MetricStream solution for ORM would include:

MetricStream ORM Framework screen

  • Risk Analysis and Risk Self Assessment: The MetricStream solution for ORM provides a centralized risk framework to document all risks faced by an organization. It supports risk assessment and computations based on configurable methodologies and algorithms giving an insight into organizations risk profile enabling the risk managers to prioritize their response strategies for optimal risk/reward outcomes. Risk Control Self Assessment (RCSA) forms a core part of the MetricStream solution. MetricStream's risk selfassessment capabilities enable organizations to document and evaluate their risk frameworks, including processes, risks, events, key risk indicators (KRI) and controls. Executive-level dashboard and reports provide visibility into the risk analysis, highlighting key risk metrics and policy compliance. Business process automation capabilities provide for real-time event escalation, automated risk processes and streamlined remediation of issues and action items.
  • Control Design and Assessments: Once the key risks are identified and prioritized, MetricStream leverages the operational risk framework to enable companies to define a set of controls that mitigate those risks. The solution also allows associated policy and procedure documents to be attached for reference. The system supports assessments based on predefined criteria and checklists and has a mechanism for scoring, tabulating and reporting results. The repository of all assessments with an easy search capability ensures that the users can check to see if a specific control was tested, access the assessment results and confirm whether it requires a remedial action plan.
  • Loss Tracking and Key Risk Indicators (KRIs): With loss event tracking, risk managers can track loss incidents and near misses, record amounts, and determine root causes and ownership. MetricStream provides statistical and trend analysis capabilities and enables end-users to track remedies and action plans. Key risk indicators (KRIs) 11 provide capabilities for tracking risk metrics and thresholds, with automated notification when thresholds are breached. MetricStream provides facilities for both manual and automatic data inputs from internal and external data sources.
  • Issue Management and Remediation: For issues arising from the assessment and auditing processes or from any other external events such as loss-events, scenario analysis or ‘near-misses', the MetricStream solution provides seamless issue management and remediation management capabilities. Once issues are identified, documented and prioritized, a systematic mechanism of investigation and remediation is set off by the underlying workflow and collaboration engine. The solution supports triggering automatic alerts and notifications to appropriate personnel for task assignments for investigation and remedial action.
  • Internal Audit: MetricStream solution provides seamless integration with internal audit management for streamlining the auditing process in the organization. It provides the flexibility to manage a wide range of audit-related activities, data and processes to support risk management. It supports all types of audits, including internal audit, operational audit, finanacial statement audit, IT audits and quality audits. Advanced capabilities like built-in remediation workflows, time tracking, email-based notifications and alerts and offline functionality for conducting at remote field sites allow organizations to implement the industry best practices for efficient audit execution and ensure integration of the audit process with the risk and compliance management system.
  • Reports and Dashboards: The solution has the ability to track risk profiles, control ownership, assessment plans, remediation status, etc. on graphical charts that can be accessed globally and display real-time information. Ability to drill-down provides an easy way to access the data at finer levels of detail. In addition to pre-configured standard risk reports, the system provides flexibility by enabling stakeholders to configure ad-hoc or scheduled reports to view metrics on a variety of parameters such as by process, by business units, by status, etc. Quarterly and monthly trending analysis along with the ability to drill-down into each report and dashboard to see the underlying details enables risk managers and process owners to stay in constant touch with the ground reality and progress on risk management programs. Automated alerts for events such as exceptions and failures eliminate any surprises and make the process predictable.

Roadmap to Advanced Measurement Approaches (AMA)
MetricStream ORM solution provides a platform for organizations to develop an integrated ORM approach which can help them qualify for Basel II AMA approach. Solution implements strategies, methodologies and risk reporting functionality to identify, measure, monitor, control and mitigate operational risk. It ensures that the organization’s internal systems and controls are “credible and appropriate”, “well reasoned and well documented”, “transparent and accessible”, and are capable of being “validated” by internal and external auditors. Moreover, it provides capability to ensure that the risk management practices are embedded across the entire value chain.

Meeting AMA qualifying criteria through MetricStream ORM solution
Qualifying Criteria MetricStream solution capability
Sound Operational Risk Management System
  • Risk & Control Self Assessment (RCSA)
  • Key Risk Indicators (KRI)
Systematic tracking of 3-5 years of historic loss data
  • Loss Event Database
  • External Loss Data interface
Measurement integrated in day-today risk management
  • Integrated RCSA & Loss Event Data
Review of management and measurement processes by internal/external audit
  • Internal Audit
  • Dashboards & Reports

References

Operational Risk Management Systems 2008 - Navigating through a fragmented market
Remarks by Governor Susan Schmidt Bies: At the International Center for Business Information's Risk Management Conference: Basel Summit, Geneva, Switzerland
OpRisk & Compliance