risk management a current challenge in banking - presentation

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    Risk Management

    a current challenge in

    BankingPriam Kasturiratna

    kastur i@sampath. lk

    4th Annual Conference on Information Technology Governance

    18th& 19thSeptember 2008, Colom bo Sri Lanka

    mailto:[email protected]:[email protected]
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    Risk Management

    a current challenge in Banking

    Changes taking place

    in the Banking and Financial

    Services Industry

    Challenges to Bankssetting-up

    Risk Management frameworks

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    Technology

    Risk Based Laws &Regulations

    Factors Driving Banking and Financial

    Service Industry

    Standardisation

    Financial ServiceInnovations

    Competition

    Climate Change

    & Global Warming

    Volatility in Energy& Commodity Markets

    Country SpecificConditions

    Changing Social &Behavioural Patterns

    Emerging Risk Types

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    Risk Based Laws and Regulations

    Worldwide

    Basel II

    Anti Money Laundering (AML) and Know Your Customer (KYC) Sarbanes Oxley Act

    Sri Lanka

    Prevention of Money Laundering Act, No. 5 of 2006

    Financial Transactions Reporting Act, No. 6 of 2006

    Companies Act, No. 07 of 2007 Directions, circulars and guidelines issued by Central Bank of Sri Lanka,

    including Basel II compliance directives.

    Laws and Regulations act as a key driver shaping the Banking industry,while generating more complexity in operations as well as in Managing Risk

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    Technology

    Dr John Lee identifies six major drivers behind Technology Investments in

    Banking and Financial Services industry.

    Dynamic IT Transformation

    Support Organic Growth

    Developing new and IT enabled revenues

    Defend Revenue sources

    Cost Optimisation Industrialised Banking

    Technology has been at the foundation of the rapid growth and innovationsin Financial Services since 1980s

    Introduction of Technology Changes Processes, Opens up new risk exposures

    inherent with the technologies adopted

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    Standardisation of Controls and

    Business Mechanisms

    1. Regulatory cooperation among Governments,

    Professional bodies, and International organisations.

    2. Cross border Laws and regulations like Basel II, AML

    Compliance, Know Your Customer regulations, Laws on

    Electronic Commerce, Sarbanes Oxley etc.

    3. Banks/Financial Service providers adapting to systems(software/hardware) offered by major global systems

    service providers.

    Three drivers silently operating to standardise the way Banking is

    conducted.

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    Financial Service Innovations

    Changing customer needs/wants

    Changing technologies

    Thinning market share and profitability

    Why Innovations are coming up in Banking/Financial

    Services?

    Bankers have emulated many non traditional

    concepts into the business, and accept higher risk

    levels to generate returns that keep their

    stakeholders happy.

    Ability to adapt to changing needs of its clientele,

    and continuous innovation have become core

    competencies of the industry.

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    Financial Service Innovations

    E-commerce/Mobile technologies Propelled by Changing lifestyles

    Most aggressively promoted retail product group

    Wealth Management and Retail Investing Services Rising number of high net worth clients

    Increasing savings levels of middle/upper middle income

    earners

    Ageing population investing retirement benefits/savings.

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    Financial Service Innovations

    Islamic Banking Singaporean and Malaysian initiatives in progress to

    establish Islamic Banking

    Islamic Financial Services Board of Malaysia has developed

    a framework for capital treatment of Islamic products &regulatory convergence with Basel II

    The swift pace of economic development of Middle Easternand other predominantly Muslim countries, combined withstrong commodity exports from many of these nations, hasfuelled demand for the development of a raft of fundinginstruments and investment products that comply withIslamic Sharia law. Monetary Authority of Singaporeestimates that global Islamic Financing market is worthUSD 300 billion, and growing at a rate of 15% every

    year Pamela Tang

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    Competition among Service Providers

    Competition from Non traditional financial serviceproviders Trying to attract clients from traditional banking

    institutions

    Telecommunications Retailing

    Real Estate

    Automotive

    Plantation sector companies have come out with many alternative

    financial service products with appeal.

    Not bound by regulations applicable to banks

    Usually gives more benefits to clients

    Higher margins compared to Banks

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    Competition among Service Providers

    Competition has affected Profitability of the industry Outsourcing has reduced this burden a little bit, but at the same time

    exposing the banks to higher levels of operational risk.

    Locally operating Banks are threatened

    Market entry by Global Banks

    Global players in the market offer branded products across thegeographical boundaries

    More demand cross border services from growing financial needs beyondlocal boundaries

    With respect to increasing globalisation, what weve seen here in Australia

    with the recent arrival of private equity into Australia is the way the market canbe changed by a global rather than a local trend. Australian banks arent very

    big in global terms. So what is not a challenge for risk professionals worldwide

    is a challenge for risk professionals in Australian banks

    Michael Hamar, Group chief risk officer, National Australia Bank

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    Volatility in Energy and Commodity

    Markets Food & energy crisis

    Increased Cost of Living

    High impact to middle/lower income groups

    Increased Operational expenses for Banks & allother organisations

    increasing operational expenses of banks will directly

    affect bottom lines

    increased credit risk due to contraction of borrowers

    repaying power

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    Climate Change and Global Warming

    Climate change will causeenormous extra costs for

    Germany in the future. Incase the global meantemperature rises up to 4.5

    degrees Celsius by 2100 -as predicted by the latestIPCC report, in case nomeasures are taken - the

    German economy mightface an additional burden ofup to 800 billion Euros by2050.

    German Institute for Economic Research (DIW)

    The UK Financial ServicesAuthority has cited climate

    change as presenting aconsiderable risk to thefinancial services sector inits annual Financial Risk

    Outlook report

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    Country Specific ConditionsSri Lanka

    Higher Market Risk - Volatility of interest and exchange rates Inflation Rates over 20%

    Unstable political situation in the north and east

    restricts healthy business growth

    poses security threats to every type of venture

    Could affect Credit, Operational and Market Risk of banks Need for strong Business Continuity Plans has become more critical

    Higher Anti Money Laundering & Terrorist Financing Risk (ForeignRemittances, top earner for the country)

    Pending issues in the country

    GSP plus

    Rising cost of living

    Issues in transportation, power etc.

    Stagnating land & housing markets

    Changes in educational system

    Restrictions in some of the overseas job markets

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    Changing Social and Behavioural Patterns

    25 years back and TODAY Response to a criminal or terrorist activity

    Bank authorising a transaction on the strength of an email.

    PC to PC free calls to a foreign country

    Epidemics, hunger and poverty loosing their place as

    major threats to human life

    Food and water contamination - a silent killer

    Stress, Mental and physical health issues are common mans

    topics

    Home Office balanced

    stress-less job

    Busy Executive with six figure income

    Increased

    Cross border activities

    White Collar

    Crimes

    Bribery,

    Corruption

    Hackers Email, Chat

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    Emerging Risk Types

    Operational Risk Business ContinuityPlanning

    AntiM

    oneyL

    aundering

    Arms and drug trade

    Human trafficking

    Bribery and corruption

    Counterparty failures

    Corporate Frauds

    Reputation Management

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    Technology

    Risk Based Laws &Regulations

    Factors Driving Banking and Financial

    Service Industry

    Standardisation

    Financial ServiceInnovations

    Competition

    Climate Change

    & Global Warming

    Volatility in Energy& Commodity Markets

    Country SpecificConditions

    Changing Social &Behavioural Patterns

    Emerging Risk Types

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    Risk Management

    Current

    Challenges in the Industry

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    The Challenges

    Increased Responsibilities

    & Involvement from Board of Directors

    Top Management

    Commitment and Support

    Setting-up Organisational Structures

    HR aspects of Risk Management

    Collecting Data &

    Managing Data Quality

    Business Manager & Risk Manager

    Integrating Risk Management

    into Business

    Training to maintain

    Risk Management Capabilities

    Risk Management and ICT

    Auditing Risk Frameworks

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    The Challenges

    From the day the board of directors and topmanagement becomes seriously committed to

    Risk Management,Board of directors, Top management andeveryone else will look forward to RiskManagers response, and assistance in

    performing their functions.

    YES, Managing Risk is a key concern for us. BUT WHOWILL BEAR THE ADDITIONAL COST OF IT

    It takes two minutes more, to open an account under NewRisk Control Procedure. Customers are not happy, it takeslonger to finish days work !@#$%^&*(!

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    Getting Top Management Commitment and

    Support Risk Management affects all employees, all processes across the bank

    Therefore it is unlikely to be successful without sponsorship from the top

    Receiving good level of sponsorship could take a number of months andsometimes years

    Starting from commitment to high level of corporategovernance, top management sponsorship shall extend totreating Risk Management as a serious aspect positivelycontributing to the organisationDemonstrating their commitment openly

    Working with Risk Manager to implement Risk Managementwithin the bank

    Accepting the ultimate responsibility for Risk Managementwithin the bank.

    Allocation of sufficient Resources

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    Getting Top Management Commitment and

    Support

    Senior management buy-in is definitely

    required. It is a necessity, but not sufficientcondition. In addition there should be buy-in

    from individual departments and individualbusiness heads. It is a complex area, because

    it looks at human behaviour- it is really a

    juxtaposition of human behaviour and riskmanagement

    Ravi Varadachari

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    Increased Responsibilities and

    Involvement from Board of Directors Directive on Corporate Governance (No 11 of 2007)

    Appoint a Board Level Sub Committee on Risk Management

    Develop Risk Management expertise within the board

    Ensure that Risk Management framework is on a sound footing

    All officers are updated with current changes in the bankingindustry worldwide.

    Companies Act 6 of 2007 Establishes joint & personal liability of directors for ensuing risk is

    managed in a sound manner

    Directors will be responsible, and increasinglyinvolved in directing top management to makingsure that the organisation & directors themselves

    are protected against risks & liabilities.

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    Setting-up Organisational Structures

    Independent Lines of Defence

    Reporting lines and proceduresProper Delegation of Risk Decision Making Authority

    Placement of Risk Managers at appropriate hierarchical level

    Regulators are increasingly seeking formal internal control assurances from regulated

    entities. Organisations should formally assess their risk and controls on an ongoing

    basis. At least once a year, management within each of the three lines of defence

    should formally attest or provide assurance on the capability maturity of the enterprise

    risk management framework as it relates to risks within their scope of authority

    Mario Micallef

    Business Units

    Risk Management

    Top Management

    Risk Management Committees

    Board of Directors

    InternalAudit

    ExternalAudit

    1 32

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    Managing HR for Risk Management

    Do we have sufficient number of competent RiskManagers to cater to all banks?

    Risk Managers may be reluctant to accept the

    standardised remuneration packages offered by traditionalbanks

    Not many banks are ready to offer premium pay levels toRisk Managers

    Risk Managers leaving for better prospects is common.

    In much worst scenarios, some banks may find that theheadhunted Risk Manager does not perform to theexpectations

    Getting the correct person for the job

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    Finding Data Analysis, Documentation and

    Communication Skills

    Most sought after skills

    Problem analysis Good use of econometrics

    Technical Writing & Documentation skills

    Communication/public relations skills

    What Bad analysis could do

    create more risk

    bad documentation could misinterpret the risk

    end up in a trash bin with disrespect.

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    Assessing a prospective Risk Manager

    Clear cut benchmarks or Industry Certifications ????

    What could be of use Financial Risk Management

    Information Security

    Business Continuity Planning

    Project Management

    Undergraduate and Masters Level qualifications are some of the useful benchmarks.

    What experience is necessary or could help? Banking

    Auditing

    Information Technology

    Project Management

    Econometrics

    Statistical Data analysis

    Legal, Technical Writing

    Organisational Re-structuring

    When it comes to selections,irrespective whether it is Credit, Market,

    Operational Risk, or Anti MoneyLaundering Compliance, banks use acombination of existing qualifications,career history, and a substantial amountof guesswork to assess suitability of anindividual for a Risk Managementposition.

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    Retaining Good Risk Managers, Job

    Satisfaction and Remuneration

    Career/Workplace Challenges faced by RiskManagers

    Improper hierarchical placement of the Risk Manager -

    Conflicting interests

    Risk Manager not having sufficient authority and independency Being overruled by the superiors lacking understanding on risk

    principals or conflict of interest

    Lack of Senior Management Sponsorship

    Risk Manager could be taken as a threat by peers/superiors

    Managing internal resistance.

    Feeling that they are underpaid in the local market

    Lack of training and development opportunities

    Career path problems

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    Retaining Good Risk Managers, Job

    Satisfaction and Remuneration

    What determines Remuneration for Sri Lankan RiskManagers

    Decision makers understanding on the contribution

    from a Risk Manager towards business success

    General pay levels of the organisation

    Whether there is a strong lobby of Risk Managers in

    the market

    The bargaining power of the prospective individualIncreased demand for experienced (Risk and Compliance) staff has pushed upsalaries significantly. There has been a year on year increase for complianceprofessionals, particularly at the junior end, which has seen a 25-30% increasein the basic salary. Temporary staff can earn upwards of 300 Sterling Pounds aday.

    Victoria Pennington

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    Retaining Good Risk Managers, Job

    Satisfaction and Remuneration Building long run Risk Expertise

    Core banking

    Lending

    Treasury

    Investments

    Econometrics

    Social sciences

    Technical Writing

    Information & CommunicationTechnology

    Card Business

    ecommerce

    Legal

    Project Management

    Auditing

    Information Security

    Business Process Re-Engineering

    A banks board ofdirectors and topmanagementneeds to display

    & act with theirstrategic vision,foresight, andlong rangeplanning

    capabilities forbuilding a strongRisk ManagementTeam over anumber of years.

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    Collecting Data & Managing Data Quality

    Risk Management relies heavily on unearthing trends or possibilities through econometrics

    large volumes of organised and dependable data

    pertaining to events over a number of years are a necessity for reliable results

    Historical data becomes a critical success factor once a bank completessetting up its basic Risk Management framework and wants to move up

    towards advanced Risk Management approaches with regulator approval.

    Banks need to recognise this early, and start data cleansing and collectionwithout delay.

    Whether available data is usable for a particular model or system

    evaluate what systems or mechanisms that they are going to use for data analysis Data requirements may vary according to the future plans

    Data cleansing will also need taking important actions/decisions, modeltesting with available data, expertise to interpret the results and refine datacollection process.

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    Collecting Data & Managing Data Quality

    As per Global Data Management Survey of Australian, US andUK companies, it was highlighted that,

    A high proportion of respondents are not verycomfortable in the quality of their data

    Most organisations still view data qualitymanagement as an IT issue, rather than an issue forsenior management, the managing director or corporate board

    Confidence in shared (industry) data from third

    parties has eroded

    Therefore, it is necessary to recognise the

    challenges early, plan ahead, and act early.

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    Integrating Risk Management Tasks into

    Business

    Incorporate Risk Management Components in to Policies

    Standards

    Procedures

    Guidelines

    Support of board of directors, top management, operations, humanresources, and training

    broad knowledge of the existing business processes

    knowledge of Risk Management

    substantial efforts in planning, documentation, and training

    The initial years on this process will be more of managing a projectthan risk management. It would take a few years to complete theprocess, and to obtain organisation wide support for new way of

    conducting daily business functions.

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    Business Manager vs. Risk Manager

    How does a Risk Manager Add Value to businessprocesses ?

    Risk Management adds control tasks into the business

    process lifecycles.

    Processes become longer and time consuming

    May need more resources

    Customer delays could occur

    Training may be needed

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    Business Manager vs. Risk Manager

    Add Value to Business vs. hampering business Success of the Risk Manager depends in getting buy-in

    from the other stakeholders

    Depends identifying thin margin between support &

    obstruction

    Clear communication of expected business benefits

    Public relations and communication are not just

    preferred skills, they are core competencies of any goodRisk Manager.

    Risk Managers true function would be to add businessvalue by ensuring higher predictability of businessoutcomes. Both Risk Managers and Business Managers

    need to assist each other in a successful business.

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    Training to maintain Risk

    Management Capabilities

    Periodic Training is crucial for Risk Managers, Board of Directors and top management

    Constant update knowledge on worldwide developments in anumber of fields Banking industry

    Overall business environment Technical developments/ICT

    New risk types

    Financial, Economic, technical & Social, etc etc Trends

    What could be risk training, continuous knowledgemaintenance ? Theoretical knowledge development

    Exposure to the industry practices, counterparties

    Knowledge sharing and exposure among local and global

    counterparts

    k d T

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    Risk Management and ICT

    ICT is a vital factor that influences everything in banking

    The volume and nature of transaction monitoring and analysisneeded cannot be done without ICT

    It is impossible to keep up with the worldwide developments inRisk Management without ICT support

    From an organisational perspective, every bank must evaluate their ITsystem needs for Risk Management from early days of planning.

    Many local banks have chosen not to become the first movers ininvesting on IT systems. Whilst there is some validity in this approach,it could be a mistake not to prepare, as one day every bank will find itimpossible to move on to advanced approaches in Risk Managementwithout IT systems.

    A di i i k k

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    Auditing Risk Frameworks

    Internal and Systems Auditors, as an independent lineof defence could contribute immensely to identify

    loopholes not detected by Risk Managers.

    Audits, a Regulatory Requirement & a Best Practise.

    1. Gaining a formal understanding of the key process & companyobjectives that may affect the operations of the process.

    2. Brainstorming risk scenarios before identifying process risks

    3. Identifying managements risk tolerance levels for variousprocess risks

    4. Assessing the risk infrastructure to evaluate the sustainabilityof the existing risk management activities.

    Paul J Sobel

    Key Steps in formulation a Risk Audit Programme

    A di i Ri k F k

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    Auditing Risk Frameworks

    Banks face two key challenges in the initialphase

    1. Engaging an auditor with

    Banking

    Systems literacy

    Exposure to Risk Management, Anti Money Laundering &

    Business Continuity Planning

    2. Rearranging existing Internal Audit framework into

    Risk Audits

    Auditing the banks Risk Framework is not to be taken lightly,

    it is urgent, and a must for true progress.

    Ri k M

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    Risk Management

    a current challenge in BankingWhat drives present & future

    of

    Banking and Financial

    Services Industry

    Challenges faced by Banks

    setting-up

    Risk Management frameworks

    Technology

    Risk Based Laws &

    Regulations

    Standardisation

    Financial ServiceInnovations

    Competition

    Climate Change

    & Global Warming

    Volatility in Energy

    & Commodity Markets

    Country Specific

    Conditions

    Changing Social &Behavioural Patterns

    Emerging Risk Types

    Increased Responsibilities

    & Involvement from BOD

    Top Management

    Commitment and Support

    Setting-up Structures

    HR aspects

    Collecting Data &Managing Data Quality

    Business & Risk Managers

    Integrating Risk Management

    into Business

    Training

    Risk Management and ICT

    Auditing Risk Frameworks

    C l i h Obj i

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    Conclusionsthe Objective

    What drives Banking industry & RiskManagement

    Underlying challenges in implementing Risk

    Management Frameworks The Objective

    Understand & appreciate the ground realities in RiskManagement & be prepared for expected challenges

    Realise the areas where involvement of the completeorganisation, proactive action and top level vision is needed,

    Initiate a healthy discussion as to how Sri Lankan Bankscould manage Risk in a better, structured manner

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    Thank you