RR-3.2.6
(a) Banks employing stress testing techniques for assessing reputational risk should seek to incorporate stress scenarios for reputational risk into their institution-wide stress testing procedures and assess the impact of reputational risk on other major risks (e.g. business or liquidity risk);
(b) In developing stress scenarios for reputational risk, banks should identify the major sources of reputational risk to which they are potentially exposed, key stakeholders that will most likely increase reputational risks in stress scenarios or an appropriate range of circumstances and events. Banks should also consider how those sources, circumstances and events may adversely affect their business prospects and financial position (including earnings, capital and liquidity), as well as generate other second round effects;
(c) Banks may face reputational risk in other aspects, such as those arising from material weaknesses in their internal risk management processes (e.g. resulting in substantial fraudulent losses) or management's failure to respond swiftly and effectively to external threats or influences (e.g. resulting in poor strategic decisions). Banks should exercise their best judgment and apply stress scenarios and parameters that suit their own circumstances and risk profile;
(d) Once the potential exposures arising from reputational concerns are identified, banks should estimate the amount of support (capital or liquidity) they may have to provide, as well as estimate potential loss under adverse market conditions. Banks should also assess the impact of reputational risk on other risks to which they may be exposed. This could be accomplished by including reputational risk scenarios in regular stress tests;
(e) Banks should assess whether there is any longer term impact on their business and operations due to reputational risk (e.g. loss of market share, customer base or business revenue). Banks should also pay particular attention to the effects of reputational risk on their overall liquidity position, taking into account both possible changes in the asset side of the balance sheet and possible restrictions on funding, should the damage in reputation result in a general loss of confidence on the part of their counterparties and customers; and
(f) Senior management should actively participate in conducting stress testing and scenario analyses for reputational risk (including the development of stress scenarios and assumptions), and review the stress testing results.
July 2018