• Risk Management Environment: Identification and Assessment

    • OM-8.2.30

      Principle 6: Senior management must ensure the identification and assessment of the operational risk inherent in all material products, activities, processes and systems to make sure the inherent risks and incentives are well understood.

      Added: October 2012

    • OM-8.2.31

      Risk identification and assessment are fundamental characteristics of an effective operational risk management system. Effective risk identification considers both internal factors (such as the bank's structure, the nature of the bank's activities, the quality of the bank's human resources, organisational changes and employee turnover) and external factors (such as changes in the broader environment and the industry and advances in technology). Sound risk assessment allows the bank to better understand its risk profile and allocate risk management resources and strategies most effectively.

      Added: October 2012

    • OM-8.2.32

      Examples of tools that may be used for identifying and assessing operational risk include:

      (a) Audit Findings: While audit findings primarily focus on control weaknesses and vulnerabilities, they can also provide insight into inherent risk due to internal or external factors;
      (b) Internal Loss Data Collection and Analysis: Internal operational loss data provides meaningful information for assessing a bank's exposure to operational risk and the effectiveness of internal controls. Analysis of loss events can provide insight into the causes of large losses and information on whether control failures are isolated or systematic. Banks may also find it useful to capture and monitor operational risk contributions to credit and market risk related losses in order to obtain a more complete view of their operational risk exposure;
      (c) External Data Collection and Analysis: External data elements consist of gross operational loss amounts, dates, recoveries, and relevant causal information for operational loss events occurring at organisations other than the bank. External loss data can be compared with internal loss data, or used to explore possible weaknesses in the control environment or consider previously unidentified risk exposures;
      (d) Risk Assessments: In a risk assessment, often referred to as a Risk Self Assessment (RSA), a bank assesses the processes underlying its operations against a library of potential threats and vulnerabilities and considers their potential impact. A similar approach, Risk Control Self Assessments (RCSA), typically evaluates inherent risk (the risk before controls are considered), the effectiveness of the control environment, and residual risk (the risk exposure after controls are considered). Scorecards build on RCSAs by weighting residual risks to provide a means of translating the RCSA output into metrics that give a relative ranking of the control environment;
      (e) Business Process Mapping: Business process mappings identify the key steps in business processes, activities and organisational functions. They also identify the key risk points in the overall business process. Process maps can reveal individual risks, risk interdependencies, and areas of control or risk management weakness. They also can help prioritise subsequent management action;
      (f) Risk and Performance Indicators: Risk and performance indicators are risk metrics and/or statistics that provide insight into a bank's risk exposure. Risk indicators, often referred to as Key Risk Indicators (KRIs), are used to monitor the main drivers of exposure associated with key risks. Performance indicators, often referred to as Key Performance Indicators (KPIs), provide insight into the status of operational processes, which may in turn provide insight into operational weaknesses, failures, and potential loss. Risk and performance indicators are often paired with escalation triggers to warn when risk levels approach or exceed thresholds or limits and prompt mitigation plans;
      (g) Scenario Analysis: Scenario analysis is a process of obtaining expert opinion of business line and risk managers to identify potential operational risk events and assess their potential outcome. Scenario analysis is an effective tool to consider potential sources of significant operational risk and the need for additional risk management controls or mitigation solutions. Given the subjectivity of the scenario process, a robust governance Framework is essential to ensure the integrity and consistency of the process;
      (h) Measurement: Larger banks may find it useful to quantify their exposure to operational risk by using the output of the risk assessment tools as inputs into a model that estimates operational risk exposure. The results of the model can be used in an economic capital process and can be allocated to business lines to link risk and return; and
      (i) Comparative Analysis: Comparative analysis consists of comparing the results of the various assessment tools to provide a more comprehensive view of the bank.s operational risk profile. For example, comparison of the frequency and severity of internal data with RCSAs can help the bank determine whether self assessment processes are functioning effectively. Scenario data can be compared to internal and external data to gain a better understanding of the severity of the bank's exposure to potential risk events.
      Added: October 2012

    • OM-8.2.33

      The bank must ensure that the internal pricing and performance measurement mechanisms appropriately take into account operational risk. Where operational risk is not considered, risk-taking incentives might not be appropriately aligned with the risk appetite and tolerance.

      Added: October 2012

    • OM-8.2.34

      Principle 7: Senior management must ensure that there is an approval process for all new products, activities, processes and systems that fully assesses operational risk.

      Added: October 2012

    • OM-8.2.35

      In general, a bank's operational risk exposure is increased when a bank engages in new activities or develops new products; enters unfamiliar markets; implements new business processes or technology systems; and/or engages in businesses that are geographically distant from the head office. Moreover, the level of risk may escalate when new products activities, processes, or systems transition from an introductory level to a level that represents material sources of revenue or business-critical operations. A bank should ensure that its risk management control infrastructure is appropriate at inception and that it keeps pace with the rate of growth of, or changes to, products activities, processes and systems.

      Added: October 2012

    • OM-8.2.36

      A bank must have policies and procedures that address the process for review and approval of new products, activities, processes and systems. The review and approval process should consider:

      (a) Inherent risks in the new product, service, or activity;
      (b) Changes to the bank's operational risk profile and appetite and tolerance, including the risk of existing products or activities;
      (c) The necessary controls, risk management processes, and risk mitigation strategies;
      (d) The residual risk;
      (e) Changes to relevant risk thresholds or limits; and
      (f) The procedures and metrics to measure, monitor, and manage the risk of the new product or activity.
      Added: October 2012

    • OM-8.2.37

      The approval process should also include ensuring that appropriate investment has been made for human resources and technology infrastructure before new products are introduced. The implementation of new products, activities, processes and systems should be monitored in order to identify any material differences to the expected operational risk profile, and to manage any unexpected risks.

      Added: October 2012