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5/22/2011   Bushra Angbeen   1
What is Risk?
 Risk may be viewed as :
  Trade off between
            “Higher Rewards” that potentially come with
     OPPORTUNITY
             and
        “Higher Risks” that have to be borne as a
     consequence of DANGER

  Deviation of actual returns from the expected
     returns

5/22/2011            Bushra Angbeen                       2
Risk Management - Defined
  Risk management can be defined as:

       “The process by which organizations
       identify, assess, control, monitor and
       measure their significant risks from
       all sources for the purpose of
       increasing short and long term value
       to stakeholders.”

  Risk Management is a continuous activity that aggregates and
     integrates risk management activities across all types of risk in
     order to achieve maximum risk-adjusted returns.
5/22/2011           Bushra Angbeen                                       3
Structure of the Basel Accord
The New Basel Capital Accord consists of three mutually enforcing pillars. All three
pillars need to be applied by banks.

           Pillar 1                     Pillar 2                     Pillar 3

     Minimum Capital              Supervisory Review            Market Discipline
      Requirements                     Process
                                 Increases the                 Expands the content and
    Establishes minimum          responsibilities and levels   improves the
    standards for                of discretion for             transparency of financial
    management of capital        supervisory reviews and       disclosures to the
    on a more risk-sensitive                                   market, with disclosure
                                 controls covering:            of:
    basis and specifically         • Processes for capital
    addresses:                       and risk profile            • Description of risk
                                     management                    management
      • Credit risk                • Capital adequacy              approaches
      • Operational risk           • Level of capital charge     • Levels of capital
      • Market Risk                • Proactive monitoring of     • Analysis of risk
                                     capital levels and            exposures and
                                     ensuring remedial             capital by businesses
                                                                   / segments
                                     action
The pervasive scope of risk points to the need for a bank-wide, comprehensive risk
management strategy, supporting structure , monitoring and control, and
measurement processes which encompass all key elements of risk
 Risk Management – Needed due to pervasive scope of risk
                                     Operational Risk
                                            • Internal fraud
                                            • External fraud
       Credit Risk                          • Employment practices
          • Corporate
                                                                      Market Risk
                                              and workplace safety
          • Consumer                                                  • Underwriting
                                            • Clients, products &
          • Counterparty                                              • Liquidity
                                              business practices
          • Sovereign                                                 • Market Price
                                            • Damage to physical
          • Model                                                     • Trading and ALM
                                              assets
          • Insurance                                                 • Model
                                            • Business disruption &
                                              system failure
                                            • Execution, delivery &
                                              process management


                                      Risk and Control Culture
   5/22/2011               Bushra Angbeen                                                 5
Focus of Basel II             Market Risk
Pillar I of Basel Accord – Minimum Capital Requirements focuses on
three major categories of Risk

      Credit Risk          Operational Risk           Market Risk




      The risk that a                               The risk of loss
    borrower may not                               arising from the
    be able to repay a   The risk of loss        fluctuating prices of
          loan.          resulting from          investments as they
                         inadequate or             are traded in the
                         failed internal            global markets.
                         processes, people
                         and systems or
                         from external
                         events.
The Basel II Accord and RBI’s Draft Guidance Note on Management of Operational Risk,
defines operational risk as:
What is operational risk ?

“The risk of loss resulting from inadequate or failed internal
processes, people and systems, or from external events.”
The definition includes legal risks but excludes strategic and
reputation risks.


 Examples of operational risks in retail branch
 (illustrative)
    Internal processes: KYC guidelines not observed resulting in fraud
    People related : Inadequate training to handle products and customer
     complaints resulting in loss of business
    Systems related : Inadequate systems to handle voluminous transactions
    External events : Natural disasters resulting in disruptions of operations




5/22/2011              Bushra Angbeen                                                  7
Features of Operational Risk

 Pervasive                          Embedded and inherent in internal processes,
                                    activities, people and systems across the entire Bank

                                    Cannot quantify / measure in the same manner as
 Measureme                          credit or market risk
 nt is a
 challenge                           quantifying individual events is a challenge. For
                                    e.g. system downtime, loss of customers, business
                                    disruption
                                     approach to be adopted for quantifying overall
                                    capital charge is a challenge


  Dynamic                           With continuous changes in operations, processes,
                                    technology, external environment of the Bank, nature
                                    of operational risk undergoes changes all the time

  Ownership
                                    Being pervasive in nature, who should own its
  –a
                                    management poses a challenge
  challenge

 5/22/2011         Bushra Angbeen                                                         8
Why is Operational Risk receiving
          increased attention ?
  Growing complexity in the banking industry (products,
   services, technology, globalization, acquisitions/mergers,
   etc.)
  Several large and widely publicized operational losses in
   recent years eg. Barings Bank, Sumitomo Corp, Diawa
   Bank (NY) Societe Generale

  Rapid pace of innovation

  Increased focus on corporate governance

  Increased global competition

  A changing regulatory capital regime.
5/22/2011        Bushra Angbeen                                 9
Approaches to minimum capital Requirement
 Basel II provides bank with a menue of approaches for quantifying the different
 type of risk under pillar one:

                                        Basel II Menu
                 • Credit Risk
                    – Standardised Approach (a modified version of
                      the existing Basel 1 approach)
                    – Foundation Internal Ratings Based Approach
                    – Advanced Internal Rating Based Approach
                 • Market Risk (unchanged from Basel 1)
                    – Standardised Approach
                    – Internal Models Approach
                 • Operational Risk
                    – Basic Indicator Approach
                    – Standardised Approach
                    – Advanced Measurement Approach



 5/22/2011             Bushra Angbeen                                          10
Operational Risk Capital : Basic
       Indicator Approach
  Use of Basic indicator or Standardised Approach for some risks and AMA
   for others is permitted.
  Cannot revert to a simpler approach if an advanced approach has been
   permitted, without supervisory approval.
 Basic Indicator Approach (BIA)
 KBIA = GI x α
 KBIA = Capital charge under Basic Indicator App.
 GI = average annual gross income last 3 yrs.
 α = 15%
 Gross income= net interest income + net non-interest income as laid down by
    supervisors/ national accounting stds.
     (i) gross of any provisions (e.g. for unpaid interest- intt. Suspense a/c);
     (ii) exclude realised profits/losses from sale of securities in banking book
        (HTM and AFS)
     (iii) exclude extraordinary/ irregular items/ Insurance Income


5/22/2011             Bushra Angbeen                                            11
The Standardized Approach (TSA)

      Banks activities mapped to 8 business lines
       framework
      Capital charge for each business line calculated by
       multiplying an indicator by a factor assigned to
       that business line
             Indicator: annual gross income (as described in BIA)
             Factor: beta () established by the BCBS
      Total capital charge is based on the 3 year average
            of the simple summation of the regulatory capital
            charges across each of the business lines in each
            year


5/22/2011               Bushra Angbeen                               12
The Standardised Approach (TSA)
              Qualifying criteria established by the Basel
               Committee plus additional criteria by national
               supervisors
              Key Basel Committee criteria for international
               active banks:
•Core for          Adequate governance framework and risk
non                 management system
internation
                   Policies and documented criteria for mapping
al active
banks               business lines & activities into the standardised
                    framework
                   Independent operational risk management function
                   Track operational risk data (including material losses) by
•Recommend          business line
ed for non
            
international
                    Report operational risk exposures to business unit
active banks        management, senior management and board
                   Validation and regular independent review of operational risk
                    assessment system
 5/22/2011                Bushra Angbeen                                        13
The Standardised Approach (TSA)
             More refined than basic indicator approach
             8 business lines.
             Gross income for each business line, not the whole
                institution.
               Gross income for a business line- same definition as in Basic
                Indicator Approach.
               Capital charge- multiply gross income by a factor (beta)
                assigned to that business line.
               Total capital charge, KTSA = Σ(GI1-8 x β1-8 )
                KTSA= capital charge The Std. App.
               GI = Gross Income
               β = multiplication factor


5/22/2011              Bushra Angbeen                                       14
Operational Risk Capital: The
            Standardized Approach (TSA)
Business Lines                       Average Gross       Beta factor   Capital
                                     Income of 3 years                 charge
Corporate Finance                    200                 18 %          36
Trading & sales                      100                 18 %          18
Retail Banking                       200                 12 %          24
Commercial Banking                   200                 15 %          30
Payments & settlements               200                 18 %          36
Agency services                      100                 15 %          15
Asset Management                     100                 12 %          12
Retail Brokerage                     100                 12 %          12
Total                                1200                              183

5/22/2011           Bushra Angbeen                                               15
OR Capital : BIA vs TSA

  Basic   Indicator Approach           Year BIA   TSA   Diff.
   and Standardised require
   much larger capital for
   operational risk than AMA            2008 3280 3710 430
  There is little difference
   between the capital needs            2009 3528 4070 542
   under BIA and TSA: both
   are high.
                                        2010 3982 4594 612
  TSA provides little relief,
   because of the very nature of
   our business composition.            2011 4883 5634 751
   (chart: Rs cr)
                                        2012 6105 7043 938

                                                             •16
•Bushra Angbeen            •5/22/2011
Advanced Measurement Approach

   Cap Required = risk measure generated by bank’s
   internal operational risk measurement system.
  Bank must fulfil qualitative & quantitative criteria
  Supervisory approval reqd. for using AMA
       Initial monitoring by supervisor for determining whether
            the approach is credible & appropriate.
  Supervisory approval reqd. for using AMA
       Initial monitoring by supervisor for determining whether
            the approach is credible & appropriate.


5/22/2011               Bushra Angbeen                             17
General Qualification Requirements for AMA

  Overall : Rigorous process consistent with
   internal risk management & MIS: appropriate
   infrastructure
  Risk Management : independent Operational
   Risk Management function
  Data & Assessment Systems : ability to
   assess risks & data consistent with activities &
   profile; transparent, systematic, credible and
   verifiable processes that incorporate the four
     data elements
5/22/2011       Bushra Angbeen                        18
General Qualification Requirements for AMA Cont’d

  Required Data Elements :
 -Internal Loss data
 -External Loss data
 -Scenario Analysis
 -Business Environment & Internal Control Factors (BEICF)
  Quantification Systems
  Data management & Maintenance : systems to support
   data collection, storage, analysis monitoring & validation
  Control, Oversight & validation : governance& oversight,
   periodic review, model validation & independent verification
   & documentation of all material aspects

5/22/2011         Bushra Angbeen                                  19
Internal Loss Data

  Definition
  Any data on exposures held in a bank’s existing or historical portfolios,
     including data provided by third parties
    Systematic process for capturing & using Operational loss data
    Operational losses must be mapped to 7 event types and 8 business lines
    Threshold for data collection , banks to demonstrate that no important
     loss data is excluded
    Operational losses related to credit risk will continue to be classified as
     credit risk
     Operational losses related to market risk will be treated as operational
     risk
    Internal loss data is used for direct input to Op.risk capital model. Also
     as input in scenario analysis & BEICF

5/22/2011             Bushra Angbeen                                               20
External Loss Data
  External loss event data means gross operational
   loss occurring at organizations other than the bank
  Obtained from vendors, newspapers, court records,
   insurance companies, data consortia, etc
  Multiple Uses
            i) Management reports
            ii) Direct input into capital model,
           iii) Supplement the lack of internal loss data
          iv) better understanding of severe but
   infrequent loss “tail”events.

5/22/2011       Bushra Angbeen                              21
Business Environment & Internal Control Factors
                   (BEICF)

  The indicators of an institution’s operational risk profile
     that reflect a current and forward looking assessment of
     its underlying risk factors
    Tools Used to support BEICF Requirement
 -   Risk Control Self-Assessment s (RCSA)
 -    Key Risk Indicators
 -   Process mapping




5/22/2011          Bushra Angbeen                                22
Scenario Analysis
  Nothing new, historically used for Business Continuity
     Planning; being expanded for use in capital

  Scenarios usually focus on developing the “severity” of
     losses on larger events for use in the tail

  Where scenarios are used:
       Qualitative adjustment
       Supplement Data

  Use of scenarios varies widely among institutions


5/22/2011          Bushra Angbeen                            23
Operational Risk Events Categories
       Operational risk categories (Level I risk
       categories) defined by Basel II and RBI:
            Internal fraud
            External fraud
            Employment practices and workplace safety
            Clients, products & business practices
            Damage to physical assets
            Business disruption & system failure
            Execution, delivery & process management


5/22/2011          Bushra Angbeen                        24
Operational Risk Events Categories

            Level 1                       Level 2         Examples (Level 3)

                                                       • transactions not
                                        Unauthorized     reported intentionally
     Internal fraud                       activity     • sanctioning
                                                         unauthorized activities
                                           Theft and   • Embezzlement/ bribes
                                            fraud      • Misappropriation of
                                                         assets




     External fraud                           Theft    • Forgery/ check kitting
                                          and Fraud
                                                       • Theft/ Robbery


                                                       • Hacking damage
                                           Systems
                                           security    • Theft of information


5/22/2011              Bushra Angbeen                                             25
Operational Risk Events Categories
              Level 1                         Level 2            Examples (Level 3)
      Employment                                            • Organized labour activity
      Practices &                            Employee       • Compensation, benefit,
      Workplace safety                       relations        termination issues
                                                            • Workers’ compensation
                                                   Safe
                                                            • Employee health & safety
                                            environment
                                                              rules


                                           Diversity and    • All discrimination types
                                           discrimination
                                            Suitability,     • Misuse of confidential
    Clients, products &                                        information
    business practices                      Disclosure,
                                               and           • Suitability / disclosure
                                            Fiduciary          issues (KYC etc.)
                                                            • Model errors/ product
                                           Product flaws      defects

 5/22/2011                Bushra Angbeen                                                  26
Operational Risk Events Categories
            Level 1                        Level 2            Examples (Level 3)
  Clients, products &                         Improper     • Insider trading
  business                                  business
                                                           • Money laundering
  practices….contd.                         practices
                                              Selection,   • Exceeding client exposure
                                          sponsorship        limits/ failure to investigate
                                          and exposure       clients as per guidelines

                                            Advisory       • Disputes over performance
                                            activity         of advisory activities

                                                            • Natural disaster losses
   Damage to physical
   activities                              Disasters and    • Human losses from external
                                            other events      sources (terrorism etc)

                                                             • Hardware/ software
   Business disruption
   and systems failure                         Systems       • Telecommunications/
                                                               Utility disruptions

5/22/2011                Bushra Angbeen                                                  27
Operational Risk Events Categories
            Level 1                            Level 2          Examples (Level 3)


   Execution, delivery                          Transaction    • Data entry error
   and process                            capture, execution   • Delivery failure
   management                              & maintenance
                                                               • Failed mandatory reporting/
                                           Monitoring &          inaccurate external reporting
                                            reporting
                                           Customer intake     • Incomplete/ missing
                                                                 documents
                                          & documentation
                                                               • Unapproved access given to
                                                  Customer
                                                                 client account
                                           / client account
                                            management         • Negligent loss to client’s
                                                                 assets
                                                   Trade
                                                               • Non-client counterparty
                                            counterparties       disputes
                                                 Vendors &
                                                               • Vendor disputes
                                               suppliers

5/22/2011                Bushra Angbeen                                                   28
Management of Operational risk is taken to mean:

   What is Operational Risk “Management” ?
Identification    Assessment                             Monitoring
                                            Mitigation
                                                         reporting
                                                                        Measuremnt


     Traditionally, Banks have always emphasized:
           prevention of frauds
           maintenance of integrity of internal controls
           reduce errors in transaction processing
           safeguard the data and systems of the Bank and so on…..
                                   Then
                                   what
                                  is new
                                     ??
     To view operational risk management as a comprehensive practice comparable
     to the management of credit risk and market risk

     To set aside a adequate capital charge to meet operational risks

   5/22/2011               Bushra Angbeen                                            29
Objectives of Operational Risk Management
Reduce Impact                             Enable the Bank reduce the probability and
and Probability of                        potential impact of losses through the
Events                                    introduction of “good practices”

                                          Enable the businesses and functional areas to
Improve Controls                          improve controls and mitigation of significant
and Mitigate Risks                        operational risks throughout the organization.


Awareness                                 Develop a common understanding of
                                          operational risk across the Bank involving every
                                          employee at all levels for pro-active
                                          management of operational risks.

Risk Ownership                            Ensure that there is clear ownership for each
                                          element of operational risk and assign clear
                                          responsibility for related day to day risk
                                          management and mitigation.

            * These objectives of operational risk management have been formalized
            by SBI in its OR policy
5/22/2011                Bushra Angbeen                                                   30
Objectives of Operational Risk Management
                                      Meet or exceed the regulatory requirements
Regulation
                                      Help in meeting the capital adequacy
                                      requirements set out by regulators and
Better Capital                        develop awareness of capital efficiency so as
Management                            to help the Bank meet its capital performance
                                      objectives

Reward for better                     Create awareness of the level of risk incurred
risk management                       and ensure that product pricing compensates
                                      for the levels of risks undertaken.
                                      Explore the range of alternatives for risk
                                      mitigation and choose the most cost effective
                                      solution to address the operational risk
                                      incurred.
Quality of Service
                                      Improve the overall quality of the bank’s
                                      products, processes, and services to customers
5/22/2011            Bushra Angbeen                                                31
Pillars of operational risk management

Policy                                           Lays down the scope, objectives and overall guidelines for
                                                 bank- wide ORM implementation


Governance                                        Lays down the position, roles/ responsibilities and reporting
structure                                         lines of the personnel involved in ORM



Process                                           Involves risk identification, validation/ assessment,
                                                  mitigation, measurement and reporting envisaged by Basel II
                                                  and RBI for effective risk management


Technology                                         Required for collection of loss data and assessment results,
                                                   aggregation of risk information and reporting


Training
                                                  For structured dissemination of ORM process across the bank
                                                  and creating robust risk management environment


            These requirements are based on guidance of Sound Practices for the Management and Supervision of
              Operational Risk (SPOR) issued by Basel II recommended by RBI in Guidance note on ORM for
              development of an appropriate risk management environment in the bank
5/22/2011                       Bushra Angbeen                                                                32
Title                     Author         Publisher
                           Suggested Reading
 An introduction to Operational Risk Kaiser & Kohne       Risk Books
 Operational Risk                      Jack L. King       Wiley Finance
 Managing Operational Risk             Douglas G. Hoffman Wiley Finance

 Sound Practices for the Mgmt &        Basel              BIS Publication
 Supervision of Operational Risk

 Operational Risk Modelling & Analysis M.Cruz             Risk Books

 Control & Self-Assessment for Risk    Ed : Wade & Wyne
 Mgt & other Practical Applications

 Integrating market, Credit &          Lampros Kalyvas,   Risk Books
 Operational Risk                      I.Akkizidis
 Operational Risk with Excel & VBA     Nigel Da Costa     Wiley


5/22/2011             Bushra Angbeen                                        33
Thank You.....!!!!!



5/22/2011   Bushra Angbeen   34

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Operational risk management (orm)

  • 1. 5/22/2011 Bushra Angbeen 1
  • 2. What is Risk? Risk may be viewed as :  Trade off between “Higher Rewards” that potentially come with OPPORTUNITY and “Higher Risks” that have to be borne as a consequence of DANGER  Deviation of actual returns from the expected returns 5/22/2011 Bushra Angbeen 2
  • 3. Risk Management - Defined  Risk management can be defined as: “The process by which organizations identify, assess, control, monitor and measure their significant risks from all sources for the purpose of increasing short and long term value to stakeholders.”  Risk Management is a continuous activity that aggregates and integrates risk management activities across all types of risk in order to achieve maximum risk-adjusted returns. 5/22/2011 Bushra Angbeen 3
  • 4. Structure of the Basel Accord The New Basel Capital Accord consists of three mutually enforcing pillars. All three pillars need to be applied by banks. Pillar 1 Pillar 2 Pillar 3 Minimum Capital Supervisory Review Market Discipline Requirements Process Increases the Expands the content and Establishes minimum responsibilities and levels improves the standards for of discretion for transparency of financial management of capital supervisory reviews and disclosures to the on a more risk-sensitive market, with disclosure controls covering: of: basis and specifically • Processes for capital addresses: and risk profile • Description of risk management management • Credit risk • Capital adequacy approaches • Operational risk • Level of capital charge • Levels of capital • Market Risk • Proactive monitoring of • Analysis of risk capital levels and exposures and ensuring remedial capital by businesses / segments action
  • 5. The pervasive scope of risk points to the need for a bank-wide, comprehensive risk management strategy, supporting structure , monitoring and control, and measurement processes which encompass all key elements of risk Risk Management – Needed due to pervasive scope of risk Operational Risk • Internal fraud • External fraud Credit Risk • Employment practices • Corporate Market Risk and workplace safety • Consumer • Underwriting • Clients, products & • Counterparty • Liquidity business practices • Sovereign • Market Price • Damage to physical • Model • Trading and ALM assets • Insurance • Model • Business disruption & system failure • Execution, delivery & process management Risk and Control Culture 5/22/2011 Bushra Angbeen 5
  • 6. Focus of Basel II Market Risk Pillar I of Basel Accord – Minimum Capital Requirements focuses on three major categories of Risk Credit Risk Operational Risk Market Risk The risk that a The risk of loss borrower may not arising from the be able to repay a The risk of loss fluctuating prices of loan. resulting from investments as they inadequate or are traded in the failed internal global markets. processes, people and systems or from external events.
  • 7. The Basel II Accord and RBI’s Draft Guidance Note on Management of Operational Risk, defines operational risk as: What is operational risk ? “The risk of loss resulting from inadequate or failed internal processes, people and systems, or from external events.” The definition includes legal risks but excludes strategic and reputation risks. Examples of operational risks in retail branch (illustrative)  Internal processes: KYC guidelines not observed resulting in fraud  People related : Inadequate training to handle products and customer complaints resulting in loss of business  Systems related : Inadequate systems to handle voluminous transactions  External events : Natural disasters resulting in disruptions of operations 5/22/2011 Bushra Angbeen 7
  • 8. Features of Operational Risk Pervasive Embedded and inherent in internal processes, activities, people and systems across the entire Bank Cannot quantify / measure in the same manner as Measureme credit or market risk nt is a challenge  quantifying individual events is a challenge. For e.g. system downtime, loss of customers, business disruption  approach to be adopted for quantifying overall capital charge is a challenge Dynamic With continuous changes in operations, processes, technology, external environment of the Bank, nature of operational risk undergoes changes all the time Ownership Being pervasive in nature, who should own its –a management poses a challenge challenge 5/22/2011 Bushra Angbeen 8
  • 9. Why is Operational Risk receiving increased attention ?  Growing complexity in the banking industry (products, services, technology, globalization, acquisitions/mergers, etc.)  Several large and widely publicized operational losses in recent years eg. Barings Bank, Sumitomo Corp, Diawa Bank (NY) Societe Generale  Rapid pace of innovation  Increased focus on corporate governance  Increased global competition  A changing regulatory capital regime. 5/22/2011 Bushra Angbeen 9
  • 10. Approaches to minimum capital Requirement Basel II provides bank with a menue of approaches for quantifying the different type of risk under pillar one: Basel II Menu • Credit Risk – Standardised Approach (a modified version of the existing Basel 1 approach) – Foundation Internal Ratings Based Approach – Advanced Internal Rating Based Approach • Market Risk (unchanged from Basel 1) – Standardised Approach – Internal Models Approach • Operational Risk – Basic Indicator Approach – Standardised Approach – Advanced Measurement Approach 5/22/2011 Bushra Angbeen 10
  • 11. Operational Risk Capital : Basic Indicator Approach  Use of Basic indicator or Standardised Approach for some risks and AMA for others is permitted.  Cannot revert to a simpler approach if an advanced approach has been permitted, without supervisory approval. Basic Indicator Approach (BIA) KBIA = GI x α KBIA = Capital charge under Basic Indicator App. GI = average annual gross income last 3 yrs. α = 15% Gross income= net interest income + net non-interest income as laid down by supervisors/ national accounting stds. (i) gross of any provisions (e.g. for unpaid interest- intt. Suspense a/c); (ii) exclude realised profits/losses from sale of securities in banking book (HTM and AFS) (iii) exclude extraordinary/ irregular items/ Insurance Income 5/22/2011 Bushra Angbeen 11
  • 12. The Standardized Approach (TSA)  Banks activities mapped to 8 business lines framework  Capital charge for each business line calculated by multiplying an indicator by a factor assigned to that business line  Indicator: annual gross income (as described in BIA)  Factor: beta () established by the BCBS  Total capital charge is based on the 3 year average of the simple summation of the regulatory capital charges across each of the business lines in each year 5/22/2011 Bushra Angbeen 12
  • 13. The Standardised Approach (TSA)  Qualifying criteria established by the Basel Committee plus additional criteria by national supervisors  Key Basel Committee criteria for international active banks: •Core for  Adequate governance framework and risk non management system internation  Policies and documented criteria for mapping al active banks business lines & activities into the standardised framework  Independent operational risk management function  Track operational risk data (including material losses) by •Recommend business line ed for non  international Report operational risk exposures to business unit active banks management, senior management and board  Validation and regular independent review of operational risk assessment system 5/22/2011 Bushra Angbeen 13
  • 14. The Standardised Approach (TSA)  More refined than basic indicator approach  8 business lines.  Gross income for each business line, not the whole institution.  Gross income for a business line- same definition as in Basic Indicator Approach.  Capital charge- multiply gross income by a factor (beta) assigned to that business line.  Total capital charge, KTSA = Σ(GI1-8 x β1-8 )  KTSA= capital charge The Std. App.  GI = Gross Income  β = multiplication factor 5/22/2011 Bushra Angbeen 14
  • 15. Operational Risk Capital: The Standardized Approach (TSA) Business Lines Average Gross Beta factor Capital Income of 3 years charge Corporate Finance 200 18 % 36 Trading & sales 100 18 % 18 Retail Banking 200 12 % 24 Commercial Banking 200 15 % 30 Payments & settlements 200 18 % 36 Agency services 100 15 % 15 Asset Management 100 12 % 12 Retail Brokerage 100 12 % 12 Total 1200 183 5/22/2011 Bushra Angbeen 15
  • 16. OR Capital : BIA vs TSA  Basic Indicator Approach Year BIA TSA Diff. and Standardised require much larger capital for operational risk than AMA 2008 3280 3710 430  There is little difference between the capital needs 2009 3528 4070 542 under BIA and TSA: both are high. 2010 3982 4594 612  TSA provides little relief, because of the very nature of our business composition. 2011 4883 5634 751 (chart: Rs cr) 2012 6105 7043 938 •16 •Bushra Angbeen •5/22/2011
  • 17. Advanced Measurement Approach Cap Required = risk measure generated by bank’s internal operational risk measurement system.  Bank must fulfil qualitative & quantitative criteria  Supervisory approval reqd. for using AMA  Initial monitoring by supervisor for determining whether the approach is credible & appropriate.  Supervisory approval reqd. for using AMA  Initial monitoring by supervisor for determining whether the approach is credible & appropriate. 5/22/2011 Bushra Angbeen 17
  • 18. General Qualification Requirements for AMA  Overall : Rigorous process consistent with internal risk management & MIS: appropriate infrastructure  Risk Management : independent Operational Risk Management function  Data & Assessment Systems : ability to assess risks & data consistent with activities & profile; transparent, systematic, credible and verifiable processes that incorporate the four data elements 5/22/2011 Bushra Angbeen 18
  • 19. General Qualification Requirements for AMA Cont’d  Required Data Elements : -Internal Loss data -External Loss data -Scenario Analysis -Business Environment & Internal Control Factors (BEICF)  Quantification Systems  Data management & Maintenance : systems to support data collection, storage, analysis monitoring & validation  Control, Oversight & validation : governance& oversight, periodic review, model validation & independent verification & documentation of all material aspects 5/22/2011 Bushra Angbeen 19
  • 20. Internal Loss Data Definition  Any data on exposures held in a bank’s existing or historical portfolios, including data provided by third parties  Systematic process for capturing & using Operational loss data  Operational losses must be mapped to 7 event types and 8 business lines  Threshold for data collection , banks to demonstrate that no important loss data is excluded  Operational losses related to credit risk will continue to be classified as credit risk  Operational losses related to market risk will be treated as operational risk  Internal loss data is used for direct input to Op.risk capital model. Also as input in scenario analysis & BEICF 5/22/2011 Bushra Angbeen 20
  • 21. External Loss Data  External loss event data means gross operational loss occurring at organizations other than the bank  Obtained from vendors, newspapers, court records, insurance companies, data consortia, etc  Multiple Uses i) Management reports ii) Direct input into capital model, iii) Supplement the lack of internal loss data iv) better understanding of severe but infrequent loss “tail”events. 5/22/2011 Bushra Angbeen 21
  • 22. Business Environment & Internal Control Factors (BEICF)  The indicators of an institution’s operational risk profile that reflect a current and forward looking assessment of its underlying risk factors  Tools Used to support BEICF Requirement - Risk Control Self-Assessment s (RCSA) - Key Risk Indicators - Process mapping 5/22/2011 Bushra Angbeen 22
  • 23. Scenario Analysis  Nothing new, historically used for Business Continuity Planning; being expanded for use in capital  Scenarios usually focus on developing the “severity” of losses on larger events for use in the tail  Where scenarios are used:  Qualitative adjustment  Supplement Data  Use of scenarios varies widely among institutions 5/22/2011 Bushra Angbeen 23
  • 24. Operational Risk Events Categories Operational risk categories (Level I risk categories) defined by Basel II and RBI: Internal fraud External fraud Employment practices and workplace safety Clients, products & business practices Damage to physical assets Business disruption & system failure Execution, delivery & process management 5/22/2011 Bushra Angbeen 24
  • 25. Operational Risk Events Categories Level 1 Level 2 Examples (Level 3) • transactions not Unauthorized reported intentionally Internal fraud activity • sanctioning unauthorized activities Theft and • Embezzlement/ bribes fraud • Misappropriation of assets External fraud Theft • Forgery/ check kitting and Fraud • Theft/ Robbery • Hacking damage Systems security • Theft of information 5/22/2011 Bushra Angbeen 25
  • 26. Operational Risk Events Categories Level 1 Level 2 Examples (Level 3) Employment • Organized labour activity Practices & Employee • Compensation, benefit, Workplace safety relations termination issues • Workers’ compensation Safe • Employee health & safety environment rules Diversity and • All discrimination types discrimination Suitability, • Misuse of confidential Clients, products & information business practices Disclosure, and • Suitability / disclosure Fiduciary issues (KYC etc.) • Model errors/ product Product flaws defects 5/22/2011 Bushra Angbeen 26
  • 27. Operational Risk Events Categories Level 1 Level 2 Examples (Level 3) Clients, products & Improper • Insider trading business business • Money laundering practices….contd. practices Selection, • Exceeding client exposure sponsorship limits/ failure to investigate and exposure clients as per guidelines Advisory • Disputes over performance activity of advisory activities • Natural disaster losses Damage to physical activities Disasters and • Human losses from external other events sources (terrorism etc) • Hardware/ software Business disruption and systems failure Systems • Telecommunications/ Utility disruptions 5/22/2011 Bushra Angbeen 27
  • 28. Operational Risk Events Categories Level 1 Level 2 Examples (Level 3) Execution, delivery Transaction • Data entry error and process capture, execution • Delivery failure management & maintenance • Failed mandatory reporting/ Monitoring & inaccurate external reporting reporting Customer intake • Incomplete/ missing documents & documentation • Unapproved access given to Customer client account / client account management • Negligent loss to client’s assets Trade • Non-client counterparty counterparties disputes Vendors & • Vendor disputes suppliers 5/22/2011 Bushra Angbeen 28
  • 29. Management of Operational risk is taken to mean: What is Operational Risk “Management” ? Identification Assessment Monitoring Mitigation reporting Measuremnt Traditionally, Banks have always emphasized:  prevention of frauds  maintenance of integrity of internal controls  reduce errors in transaction processing  safeguard the data and systems of the Bank and so on….. Then what is new ?? To view operational risk management as a comprehensive practice comparable to the management of credit risk and market risk To set aside a adequate capital charge to meet operational risks 5/22/2011 Bushra Angbeen 29
  • 30. Objectives of Operational Risk Management Reduce Impact Enable the Bank reduce the probability and and Probability of potential impact of losses through the Events introduction of “good practices” Enable the businesses and functional areas to Improve Controls improve controls and mitigation of significant and Mitigate Risks operational risks throughout the organization. Awareness Develop a common understanding of operational risk across the Bank involving every employee at all levels for pro-active management of operational risks. Risk Ownership Ensure that there is clear ownership for each element of operational risk and assign clear responsibility for related day to day risk management and mitigation. * These objectives of operational risk management have been formalized by SBI in its OR policy 5/22/2011 Bushra Angbeen 30
  • 31. Objectives of Operational Risk Management Meet or exceed the regulatory requirements Regulation Help in meeting the capital adequacy requirements set out by regulators and Better Capital develop awareness of capital efficiency so as Management to help the Bank meet its capital performance objectives Reward for better Create awareness of the level of risk incurred risk management and ensure that product pricing compensates for the levels of risks undertaken. Explore the range of alternatives for risk mitigation and choose the most cost effective solution to address the operational risk incurred. Quality of Service Improve the overall quality of the bank’s products, processes, and services to customers 5/22/2011 Bushra Angbeen 31
  • 32. Pillars of operational risk management Policy Lays down the scope, objectives and overall guidelines for bank- wide ORM implementation Governance Lays down the position, roles/ responsibilities and reporting structure lines of the personnel involved in ORM Process Involves risk identification, validation/ assessment, mitigation, measurement and reporting envisaged by Basel II and RBI for effective risk management Technology Required for collection of loss data and assessment results, aggregation of risk information and reporting Training For structured dissemination of ORM process across the bank and creating robust risk management environment These requirements are based on guidance of Sound Practices for the Management and Supervision of Operational Risk (SPOR) issued by Basel II recommended by RBI in Guidance note on ORM for development of an appropriate risk management environment in the bank 5/22/2011 Bushra Angbeen 32
  • 33. Title Author Publisher Suggested Reading An introduction to Operational Risk Kaiser & Kohne Risk Books Operational Risk Jack L. King Wiley Finance Managing Operational Risk Douglas G. Hoffman Wiley Finance Sound Practices for the Mgmt & Basel BIS Publication Supervision of Operational Risk Operational Risk Modelling & Analysis M.Cruz Risk Books Control & Self-Assessment for Risk Ed : Wade & Wyne Mgt & other Practical Applications Integrating market, Credit & Lampros Kalyvas, Risk Books Operational Risk I.Akkizidis Operational Risk with Excel & VBA Nigel Da Costa Wiley 5/22/2011 Bushra Angbeen 33
  • 34. Thank You.....!!!!! 5/22/2011 Bushra Angbeen 34