This document discusses using key risk indicators (KRIs) to measure operational risk in wealth management services. It recommends starting with simple KRIs like the number of investment products, number of staff selling products, and number of new customers. More specific KRIs could include the number of high-risk products or inexperienced staff. The document outlines analyzing KRIs over time and across branches to identify trends or outliers. It also discusses setting trigger limits and using KRIs to assess risk mitigation effectiveness. Overall, the document promotes adopting a KRI program to systematically monitor operational risk levels and satisfy regulatory requirements.
1. Managing Operational Risk
with Key Risk Indicators
Dr. LAM Yat-fai (林日辉博士林日辉博士林日辉博士林日辉博士)
Doctor of Business Administration (Finance)
CFA, CAIA, FRM, PRM, MCSE, MCNE
PRMIA Award of Merit 2005
E-mail: quanrisk@gmail.com
2
Agenda
Measuring operational risk with
KRIs
Implementing a KRI program
3 4
2. 5 6
7
Case: The lessons from selling Lehman
Brothers’ investment products
Do you know how many
investment products you are
selling?
Do you know how many Lehman
Brothers-related transactions are
processed in the past 3 months?
Do you know how many
customers you have?
Do you know how many new
customers you have in the last
quarter?
Do you know whether your marketing
staff have mis-communicated with your
clients?
Do you know whether your investment
product documents are compliant with
the SFC’s regulatory requirements?
Do you know how many marketing staff
have undergone proper product training?
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Basel III classification
on operational failures
1. Internal Fraud
2. External Fraud
3. Employment Practices and Workplace Safety
4. Clients, Products, & Business Practice
5. Damage to Physical Assets
6. Business Disruption & Systems Failures
7. Execution, Delivery, & Process Management
3. 9
Your questions on wealth
management services
Return
How much profit to be generated from wealth management services?
Risk
What are the major operational failures (high frequency and/or
serious loss) associated with wealth management?
How do you measure this risk? What are the current risk level?
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Wealth management services: questions
on operational risk
Is the operational risk level
acceptable, too high or too low?
Is the operational risk level
increasing or decreasing during
the last 12 months?
Which branch and/or investment
product contributes the most
operational risk?
If the operational risk level is too
high, how to plan for the
mitigation actions?
How to assess whether a
mitigation action is effective?
How to set limits for operational
risk level?
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Think realistically…
There is no perfect indicator
You should look for some indicators that are associated with
operational failures
There is no single right indicator
Your audit department and the bank regulator simply ask whether your
know the operational risk and how you measure it. It is hard for them to
prove whether you are right or wrong
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Operational risk measurement
Qualitative
Low, medium, high
Subjective
Difficult to compare
Quantitative
Numerical
Objective
Relatively easy to compare
4. 13
What is key risk indicator (KRI)?
Indicator
Quantifiable
Risk
Sensitive to risk
Key
Only a few
Definition from the HKMA: KRIs
are primarily a selection from a pool
of operations or control indicators
identified and being tracked by
various functions of a bank…
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KRI report for settlement operations of a
major bank in London
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What regulators expect on KRIs?
KRIs may be early warning
signals
KRIs help predict risk
KRIs help the management
know where the risks are
KRIs help the management
know the current risk and
its recent trends
KRIs help the management
set risk limits and action
plans
16
How do you benefit from KRIs?
To measure operational
risk in numbers
To compare operational
risk among business
units
To exhibit trend of
operational risk
To analyze level of
operational risk
To measure effectiveness of
operational risk mitigation
actions
To communicate operational
risk level bottom up
5. 17
Incentives for a corporate
deployment of KRIs
For audit department
Help identifying high risk areas and outliers
Thus focusing audits on the weakest link
For business department
An objective and on-going risk monitor system put in place
Justify less audit if you are not an outlier
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Characteristics of good KRIs
Intuitive and
simple
Easy to observe
and measure
Recorded automatically
Several KRIs on a single
risk dimension
No contradiction
Less overlapping
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Answer: Possible KRIs for wealth
management services
No. of investment products
No. of regulatory guidelines on selling investment products
No. of staff selling investment products
No. of customers acquired investment products
Monthly sales target of investment products
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More specific KRIs for wealth
management services
No. of high risk investment products
No. of regulatory guidelines issued
last year on selling investment
products
No. of staff selling investment
products with experience less than
one year
No. of customers acquired
investment products with
mis-matched risk level
Residual sales target of
investment products
6. 21
How to analyze KRIs?
Peer analysis
Which branch is the
most risky?
Which branch is the least
risky?
Trend analysis
Is the operational risk
increasing?
Is the operational risk
reducing?
Threshold analysis
At which level has material
operational failure started to
emerge?
At which level has even minor
operational failure never
observed?
Statistical analysis
What is the average risk level?
What is the distribution of risk
level?
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Peer analysis
Monthly no. of transactions per teller
-
500
1,000
1,500
2,000
2,500
3,000
3,500
A
verage
Sha
Tin
Eastern
K
w
un
Tong
Yuen
Long
K
w
aiTsing
Tuen
M
un
W
ong
TaiSin
SaiK
ungSham
ShuiP
oK
ow
loon
C
ity
TaiPo
Tsuen
W
an
High risk trigger level
Inefficient trigger level
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Trend analysis
Monthly no. of transactions per teller
(Shatin branch)
-
500
1,000
1,500
2,000
2,500
3,000
3,500
Jan-2010 Feb-2010 Mar-2010 Apr-2010 May-2010 Jun-2010 Jul-2010 Aug-2010 Sep-2010 Oct-2010 Nov-2010 Dec-2010
High risk trigger level
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Effectiveness of mitigation plan
Monthly no. of transactions per teller
(Shatin branch, with two tellers re-deployed from Tai Po in 2011)
-
500
1,000
1,500
2,000
2,500
3,000
3,500
Apr-2010 May-2010 Jun-2010 Jul-2010 Aug-2010 Sep-2010 Oct-2010 Nov-2010 Dec-2010 Jan-2011 Feb-2011 Mar-2011
High risk trigger level
7. 25
Setting trigger limits
High risk trigger level
The level of KRI at which
material operational failure
starts to emerge
Inefficient trigger level
The level of KRI at which even
minor operational failure never
occurred, an indication of
inefficiency
Trigger limits could only be set
after a relevant KRI system is in
place for a sufficient long history,
e.g. one business cycle
Some trigger examples
90th percentile
Mean + 1.67 SD
The KRI level 3 month before a
failure occur
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Your benefits (again)
To satisfy regulatory
requirements
To minimize audit findings
To demonstrate a high
standard of OPM
compatible with major
international banks
To prevent potential
operational failures
To justify additional
resources
To disclaim liabilities in
case of request on
additional resources
disapproved
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Disadvantages of KRIs
Cost of do business
Backward looking
No standard KRIs
Long data history to build
KRI database
Unclear causal relationship
between operational loss
and KRIs
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Agenda
Measuring operational risk with
KRIs
Implementing a KRI program
8. 29
Who design the KRIs?
You design your own KRIs
Only you know which KRIs
are the best
Not compliance department
They specify more KRIs to
satisfy regulators
Not external auditors
They specify more KRIs to
justify their audit fee
Not external consultants
They specify useless KRIs
to charge more
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Number of KRIs
KRIs must be key
Preparation of KRIs is costly
Less then no. of productive staff in your
department
Inconsistency among KRIs are difficult
to explain
More KRIs trigger more questions from
management, auditors and regulators
Rule of thumb
for a simple
business line
Between 5 to 7
At least 3
At most 12
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Common KRIs
Annual gross revenue
No. of critical operational failures per year
No. of customers per staff per month
No. of transactions per staff per month
Transaction amount per staff per month
Time required to process one transaction
No. of low, medium, high audit findings
Results from control self-assessment
…
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Roll out strategy
Start with each
business line
Then product and branch
Start with simple
numbers
No. of customers
No. of low, medium and
high risk customers
No. of mis-match selling
Start with quarterly
measures
Conduct annual review
9. 33
Preparing management reports
Peer analysis
e.g. by branch
Trend analysis
e.g. from last 12 months
Threshold analysis
e.g. did outliers experienced
material failures?
Statistical analysis
e.g. mean, standard
deviation, relationship with
material operational failures
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Common misunderstandings
The more KRIs, the better OPM
Limit KRIs only to a few KEY
Assign “Low”, “Medium”,
“High” value to a KRI
Use numeric as much as
possible
External consultants can design
KRIs
They charge you by copying
Bank A’s KRIs to your bank
They charge Bank B by
copying your bank’s KRIs to
Bank B
KRIs are forward looking
KRIs only tell you as they are
Plan to roll out a perfect KRI
system
You cannot improve your KRI
system next year
KRI is the most important task
You are paid because of
creating revenue
KRI is only one of the few
major OPM methods
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Use of external consultants
Bring in experiences from regulators and other banks
Put in place the skeleton of an KRI framework
Introduce a culture of KRIs
Conduct training on KRIs
Design MIS systems and reports
But, external consultants can never design KRIs for your
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Final advice
Start your KRI system tomorrow
Start with simple and easy KRIs
10. 37
Your exercise
List three major business lines in your
department
List three KRIs for each business line
Specify how to collect the KRIs
Your opinions
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