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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
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?
8
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
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?
10
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?
10
11
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
11
12
Operational risk measurement
Qualitative
Low, medium, high
Subjective
Difficult to compare
Quantitative
Numerical
Objective
Relatively easy to compare
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…
14
KRI report for settlement operations of a
major bank in London
15
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
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
18
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
19
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
20
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
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?
22
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
23
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
24
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
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
26
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
27
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
28
Agenda
Measuring operational risk with
KRIs
Implementing a KRI program
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
30
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
31
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
…
32
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
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
34
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
35
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
36
Final advice
Start your KRI system tomorrow
Start with simple and easy KRIs
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
http://sites.google.com/site/quanrisk

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18.2 internal ratings based approach
 
17.2 the basel iii framework
17.2   the basel iii framework17.2   the basel iii framework
17.2 the basel iii framework
 
16.2 the ifrs 9
16.2   the ifrs 916.2   the ifrs 9
16.2 the ifrs 9
 
15.2 financial tsunami 2008
15.2   financial tsunami 200815.2   financial tsunami 2008
15.2 financial tsunami 2008
 
14.2 collateralization debt obligations
14.2   collateralization debt obligations14.2   collateralization debt obligations
14.2 collateralization debt obligations
 
12.2 cds indices
12.2   cds indices12.2   cds indices
12.2 cds indices
 
11.2 credit default swaps
11.2   credit default swaps11.2   credit default swaps
11.2 credit default swaps
 
10.2 practical issues in credit assessments
10.2   practical issues in credit assessments10.2   practical issues in credit assessments
10.2 practical issues in credit assessments
 
09.2 credit scoring
09.2   credit scoring09.2   credit scoring
09.2 credit scoring
 
08.2 corporate credit analysis
08.2   corporate credit analysis08.2   corporate credit analysis
08.2 corporate credit analysis
 
07.2 credit ratings and fico scores
07.2   credit ratings and fico scores07.2   credit ratings and fico scores
07.2 credit ratings and fico scores
 
06.2 credit risk controls
06.2   credit risk controls06.2   credit risk controls
06.2 credit risk controls
 
05.2 credit quality monitoring
05.2   credit quality monitoring05.2   credit quality monitoring
05.2 credit quality monitoring
 
04.2 heterogeneous debt portfolio
04.2   heterogeneous debt portfolio04.2   heterogeneous debt portfolio
04.2 heterogeneous debt portfolio
 
03.2 homogeneous debt portfolios
03.2   homogeneous debt portfolios03.2   homogeneous debt portfolios
03.2 homogeneous debt portfolios
 
02.2 credit products
02.2   credit products02.2   credit products
02.2 credit products
 

2. op risk and aml

  • 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? 8 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? 10 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? 10 11 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 11 12 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… 14 KRI report for settlement operations of a major bank in London 15 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 18 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 19 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 20 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? 22 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 23 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 24 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 26 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 27 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 28 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 30 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 31 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 … 32 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 34 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 35 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 36 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 http://sites.google.com/site/quanrisk