Presentation on theme: "R92723030 沈子喬 R92723037 陳禹君 R92723049 蔡少懷 R92723030 沈子喬 R92723037 陳禹君 R92723049 蔡少懷 Presented by Operational and Technology Risks."— Presentation transcript:
R 沈子喬 R 陳禹君 R 蔡少懷 R 沈子喬 R 陳禹君 R 蔡少懷 Presented by Operational and Technology Risks
Part II Operational Risk in Basel Ⅱ Part III Operational Risk Management In Practice Part I The Introduction to Operational Risk I n d e x
Step 1: An idea of operational risk Step 2: Technology and Financial Service Step 3: The Effect of Technology on Revenues and Costs! Step 4: Technology in Payments System Step 5: Managing Operational Risk Introduction to Operational Risk
Part I Introduction to Operational Risk Difficult to measure, yet crucial ！
An idea of Operational Risk Major risks faced by banks! Source: The New Basel Capital Accord: Basel II, Jan 2001
What is Operational Risk ? Operational risk and inclusive of technological risk is the risk of loss resulting from inadequate or failed internal processes 、 people 、 and systems or from external events. Some FIs add “Reputational risk and strategic risk as part of a broader definition (e.g., due to a failed merger). Definition by BIS,Working Paper on the Regulatory Treatment of Operational Risk, Sep, 2001 An idea of Operational Risk direct and indirect
1. Technology (e.g., technological failure and deteriorating systems) 2. Employees (e.g., human error and internal fraud) 3. Customer relationships (e.g., contractual disputes) 4. Capital assets (e.g., destruction by fire or other catastrophes) 5. External (e.g., external fraud) What are the source of Operational Risk ? An idea of Operational Risk
A summary of operational risks faced by FIs Table 14-8 Introduction to Operational Risk Employee turnover Key personnel risk Fraud risk Error Rogue trading Money laundering Confidentiality breach Programming error Model risk Mark-to-market error Management information IT systems outage Telecommunications failure Technology provider failure Contingency planning Technology Risk Employee Risk Customer Risk Contractual disagreement Dissatisfaction Default Capital Asset Risk Safety Security Operating Costs Fire / flood External Risk External fraud Taxation risk Legal risk War Collapse of markets Reputation risk Relationship risk
How can operational failure affect an FI? Tearful Lessons!! The effects of operational failure! 楊瑞仁在國票案中吞占國票１０２. ２億元 國 票 案國 票 案 資深法務人員 ( 劉偉杰 ) 監守自盜３０億元 理 律 案理 律 案 年僅 28 歲的高級期貨交易員 Nick Lesson ，以短短 2 年半的時間， 搞 倒具有 232 年歷史的霸菱銀行，最後落得以 1 英鎊象徵性的價格， 被荷蘭國際銀行（ ING ）所收購。 霸 菱 案霸 菱 案 An idea of Operational Risk
The application of computers, audio and visual communication systems, and other information systems to an FI’s production of service. 1. Lower costs by combining labor and capital in a more efficient mix. 2.Increased revenues by allowing a wider array of financial services to be produced or innovated and sold to customers. Technology The most important factor affects the profitability and riskness of modern FIs. Technology and Financial Service
Wholesale Financial Services How modern technology affect an FI’s profit-producing area ? Technology improves FIs’ abilities to provide cash management or working capital services to corporate customers, who start to recognize that: 1.Excess cash balances result in a significant opportunity cost. 2.Corporate need to know cash or working capital position on a real-time basis. Technology and Financial Service
企業金融 Wholesale Financial Services The services provided to help corporate customer manage their financial position. 1.Controlled disbursement accounts. 2. Account reconciliation. 3. Wholesale lockbox. 4. Electronic lockbox 5. Funds concentration. 6. Electronic funds transfer 7. Check deposit services 8. Electronic initiation of letters of credit. 9. Treasury management software. 10. Electronic data interchange 11. Facilitating business-to-business e-commerce 12. Electronic billing 13. Verifying identities 14. Assisting small business entries into e-commerce. Technology and Financial Service
一般企業金融產品 資金管理 風險管理 外匯業務 OBU 國際金融業務 授信業務 信託業務 資本市場金融產品 台幣資本市場金融產品 外幣資本市場金融產品 企業電子金融產品 金融電子資料交換系統 (FEDI) 企業資金管理系統 企業貸款集中支付管理系統 整批轉帳系統 人事薪資管理系統 股利代發管理系統 各種轉帳代收業務 Technology and Financial Service 企業金融 Wholesale Financial Services In Taiwan, banks offer such service for corporate customers as follows:
A typical customer transaction through a branch or phone call costs a customer about $1, while a similar online transaction costs just $0.02 ! Some of the most important retail payment product innovations include: 1.Automated teller machines (ATMs) 2.Point-of-sale (POS) 3.Home banking 4.Preauthorized debits/credits. Technology and Financial Service 個人金融 Retail Financial Services Researched by Merrill Lynch 5.Paying bills via telephone 6.Smart-cards (store-value cards) 7.On-line banking 8. billing
By virtue of technology FIs no more made money only by interest spread earnings financial service provider They are financial service provider now ! Technology and Financial Service
Technology can improve FI’s profitability through means of: Electronic processing and storage system The Effect of Technology on Revenues and Costs! Profit Function Interest income - Interest expense Other income- Noninterest expense Provision for loan losses Earnings or Profit before taxes + - = Increase Interest Income Lower Interest Expense Increase Other Income Decrease Noninterest Expense a)Link to interbank lending market. b) Originate and sell commercial paper, entering lower-cost funding market. Offering innovative products and better payment system Cross Selling (Data Mining)
Earnings and Other Data for All Insured Banks Source: Federal Deposit Insurance Corporation website Update Table 14-1 The Effect of Technology on Revenues and Costs!
Underscoring the importance of operating costs is the fact that non-interest expenses gradually exceeds interest expense. Noninterest income of banks increase steadily. The Effect of Technology on Revenues and Costs!
Make or Break? Profitability V.S. Technology! The effect of regulation and regulatory changes can not be ignored! The Effect of Technology on Revenues and Costs! Product revenue side Operating cost side
Technology on product revenue side 1. Cross-marketing both new and existing products to customers. 2. Increase the rate of innovation of new financial products. 3. Service quality and convenience. The Effect of Technology on Revenues and Costs!
Technology on Operating cost side In general, technology may favorably affect an FI’s cost structure by allowing it to exploit either economies of scale or economies of scope. The Effect of Technology on Revenues and Costs!
Economies of scale As the output of an FI increases, its average costs of production fall. ACi = Average costs of the ith FI TCi = Total costs of the ith FI Si = Size of the FI measured by assets, deposits, or loans. Cost-lowering effects of technology on FIs of all size but with the greatest benefit accruing to those of the largest size. The Effect of Technology on Revenues and Costs!
Yet FIs may face diseconomies of scale and other shape of AC function ! The Effect of Technology on Revenues and Costs! Economies of scale S* is the most efficient size for an FI to invest. Diseconomies of scale! As the output of an FI increase, its average costs of production increase. (e.g. Excess capacity, integration problems, cost overruns, cost control problems)
The FI’s abilities to generate synergistic cost savings through joint use of inputs in producing multiple products. AC A+B [X 1, X 2 ] < AC A [X 1,0] + AC B [0,X 2 ] Nevertheless, diseconomies of scope may occur instead! The Effect of Technology on Revenues and Costs! Economies of scope
Testing for Economies of Scale and Economies of Scope FIs must specify both the inputs to their production process and the cost of those inputs The Production Approach The Intermediation Approach C = f (y, w, r) C = f (y, w, r, k) w = Wage costs of labor r = Rental costs of capital y = Output of services k = The cost of funds for the FI. The intermediary uses to produce intermediated service. The Effect of Technology on Revenues and Costs!
Can earnings always exceed expense? Investment on technology allows an FI to earn potentially higher profits, but not for sure because: Agency Conflicts The Effect of Technology on Revenues and Costs! A growth-oriented investment may be in consistent with stockholder’s value-maximizing objectives. NPV (Technology investment project) < ０. Io = Initial capital outlay for developing an innovation or product at time 0 Ri = Expected net revenues or cash flows from product sales in future years i, i = 1…..N d = FI’s discount rate reflecting its risk-adjusted cost of capital The initial cash outlay and future costs related to these investments are unable to be offset.
Empirical Findings 1.Only a small part of the cost differences among FIs in any size class can be economies of scale or scope. 2.A majority of the studies shows the relatively low payoff from technological innovation. 3.Large FIs tend to be more efficient in revenue generation than smaller FIs and that such efficiencies may well offset scope and scale cost inefficiencies related to size. 4.Real benefits of technological innovation are difficult to measure through traditional studies. The Effect of Technology on Revenues and Costs!
American Practice 1. Fed wire operated by Federal Reserve 2.Privately operated Clearing House Interbank Payments System (CHIPS) Table 14-5 This trend can partly be attributed to the development of “sweep accounts”. Sweep accounts Customers can automatically switch funds from high-reserve requirement checking accounts into low-reserve requirement savings accounts In 2000 The average daily Fedwire funds value $1.5 trillion The average daily CHIPS value $1.2 trillion Technology in Payments System The two dominant wire transfer systems are
6 major risks have arisen along with the growth of wire transfer systems. 1.Daylight Overdraft Risk 2.International Technology Transfer Risk 3.Crime and Fraud Risk 4.Regulatory Risk 5.Tax Avoidance 6.Competition Risk Technology in Payments System
1. Daylight Overdraft Risk When a bank’s reserve account at the Fed becomes negative within the banking day. A possibly greatest potential sources of instability in the financial markets today! Under Federal Reserve Act, the member bank’s end-of day reserve position cannot be negative. Daylight Overdraft Technology in Payments System
Settlement failure could result in disastrous systemic crisis. Large banks seek to borrow funds in the afternoon to cover for running daylight overdraft. Under regulation J, the Fed guarantees payment finality for every wire transfer message. All within-day transfers are provisional, and become final only at the end of the day. 1. Daylight Overdraft Risk Fedwire CHIPS Technology in Payments System
The efforts to alleviate daylight overdraft risk. 1.CHIPS members contributed to a special escrow fund. 2. Implementing Regulation F: Banks, thrifts, and foreign banks must develop internal procedures of benchmarks to limit their settlement to other FIs. 1. Daylight Overdraft Risk Technology in Payments System
What happens in Taiwan… Negative Intervention ( 負數操作 ) 存款準備金的提存期間為一個月，銀行雖然每日計算當日超額準備的變化，但並 不需要每日提足至法定水準，只要至每月 3 日的最後期限，銀行提存的存款準備積數 總額，能補足應提的法定額度即可。 因此銀行於月初行性支出高峰時，市場資金水位下降，銀行實提準備低於應提準 備的水準，造成負數缺口，於短期利率上揚時，擴大準備部位負數缺口，將資金投 入票券等短期投資，待中旬資金寬鬆、短期利率走低之際，再從事正數操作，出脫 手中票券，以填補部位缺口。 1. Daylight Overdraft Risk Technology in Payments System
Wire transfers as methods of payment has resulted in new problems regarding theft, data snooping, and white-collar crime. (e.g. ATM card fraudulent duplication) The prohibition of the use of technological innovations limits FIs’ profitability. 2. International Technology Transfer Risk 3. Crime and Fraud Risk Technology in Payments System
The government regulation imposed in the adoption of some financial service limits FIs’ profitability. Internal pricing mechanisms minimize firms’ tax burden, yet erode governments’ tax base. (e.g. BVI account) Technology eposes existing FIs to the increased risk of erosion of their franchises as costs of entry fall and the competitive landscape changes. (e.g. 裕融企業, 會計事務所介入保管 業務 ) 4. Regulatory Risk 5. Tax Avoidance 6. Competition Risk Technology in Payments System
Taiwanese Practice ‧ 金融機構跨行資訊系統之營運。 ‧ 金融機構間跨行業務之帳務清算。 ‧ 辦理與金融機構間業務相關之各類資訊傳輸、交換。 ‧ 金融機構間資訊系統災變備援之服務。 ‧ 金融機構間業務自動化之規劃、諮詢及顧問業務。 ‧ 其他經財政部指定或核准辦理之有關業務。 財金資訊公司前身為「金融資訊服務中心」（簡稱金資中心）。民國七十三年十月財政 部為促進金融業之資源共享、資訊互通、並提昇整體金融自動化層面，經報奉行政院核 定設立金資中心，負責全國金融機構跨行資訊網路之規劃、設計、建置工作。主要業務 為金融機構跨行資訊系統的規劃開發及跨行資訊網路的營運。 The role of FISC (Financial Information Service Co. LTD. ) Technology in Payments System
自動化機器共用系統 通匯系統 信用卡服務系統 金融 XML 業務 The business lines: What is FEDI ？ 金融電子資料交換（ Financial Electronic Data Interchange ， FEDI 、金融 EDI ）係指企業或個人利 用電腦作業，以特定的標準格式（採用聯合國 UN/EDIFACT 所制定的標準訊息），經由專線撥接與 銀行直接連線，在安全無虞的環境下進行企業或個人的付款、轉帳等資金調撥作業。 Taiwanese Practice 行動銀行服務系統 資訊查詢系統 轉帳卡服務系統 I C 金融卡服務系統 資訊系統災變備援服務 FEDI 服務系統 代繳代發系統 網際網路作業系統 資訊媒體儲存服務 Technology in Payments System
Who is in charge of its failure !! Taiwanese Practice 10 / 20/ 2003 所有銀行的跨行轉帳全面 “ 癱瘓 ” 通訊控制機故障 前員工及外包人員三人和偽卡集團勾結，外洩信 用卡持卡的人資料，遭這個信用卡偽卡集團盜刷 的金額，超過 30 億元 信用卡內碼資料外洩 Technology in Payments System
Technological innovation serves to provide completely different financial services, yet it also exposes FIs’ to the risks of a distinct category. The Operational Risk The risk that FIs’ can ignore no more! Technology in Payments System
The efforts to help FIs manage losses due to operational risk. Managing Operational Risk Training, development, and review of employees Loss Prevention Planning, organization, back-up. (e.g., computer systems.) Loss Control External insurance. (e.g., catastrophe insurance) Loss Financing FI capital. Loss Insulation RME: Extent of risk management efforts Figure 14-6 Operational Risk Management Effort
Regulatory Efforts to manage operational risk 1. Customer Protection a. Does FI customers have the right to opt out of any private information sharing an FI may want to pursue? The issues brought.. 依據法令規定，金控集團旗下子公司可以交叉分享包括姓名、生日、身份證字號與電話 地址的基本客戶資料。子公司如果想相互分享客戶金融交易細節，必須事前向客戶得到書 面同意。 但若消費者買的是結合銀行、證券、保險等功能的綜合性商品，就不得不向金控集團旗 下的各個子公司，透露攸關個人財富與金融交易的資訊。例如，中信金控的「萬股通」， 可連結往來券商進行自動跨券商轉帳作業，並提供最高 50 萬元新台幣的金融卡信用額度， 自動結合補差額功能。因此「萬股通」客戶的帳戶資料，將會同時透露給中信金控旗下的 銀行與券商。 Managing Operational Risk
電腦處理個人資料保護法 b. Do Internet transactions and electronic storage of private information expose FI customer to the security risk. Regulatory Efforts to manage operational risk 1. Customer Protection The issues brought.. 但我國執法不力，以致造成花旗銀行資料外洩的情況，嚴重危 害金融交易的安全性。 Managing Operational Risk
Operational risks “are sufficiently important for banks to devote resources to quantify the level of such risks and to incorporate them into their assessment of their overall capital adequacy.” FIs have lost over $ 200 billion due to operational risk since Researched by Operational Research Inc. Basel Committee on Banking Supervision in 1999 Basel Committee Regulatory Efforts to manage operational risk ２. Operational Fisk and FI Insolvency Managing Operational Risk
Part II Operational Risk in Basel Ⅱ Part III Operational Risk Management In Practice Part I The Introduction to Operational Risk I n d e x
Operational Risk in Basel Ⅱ Loss Data Collection Structure of Basel Ⅱ for “OpRisk” –Pillar 1 : (MRC) Minimum Required Capital Basic Indicator Approach (BIA) Standardized Approach (SDA) Advanced Measurement Approach (AMA) –Pillar 2 : Supervisory Review Process –Pillar 3 : Disclosure Operational Risk in Basel Ⅱ
Loss Data collection Breaking loss data into “Business Lines” and “Event Types”. Operational Risk in Basel Ⅱ
Business line / event types classification BUSI- NESS UNITS Level 1 Business Lines Internal Fraud External Fraud Employment Practice & Workplace Safety Clients, Products & Business Practices Damage to Physical Assets Business Disruption & System Failures Execution, Delivery & Process Mgt.** Invest- ment Banking Corporate Finance* Trading & Sales BankingRetail Banking Commercial Banking Payment & Settlement Agency Services & Custody OthersAsset Mgt.** Retail Brokerage Including Municipal/Gov’t Finance and merchant banking. ** Mgt. = management Resources: Basel Committee on Banking Supervision, “Working Paper on Regulatory Treatment of Operational Risk,” September 2001.www.bis.org Joint Combination Corprate finance( 企業財務規劃 ) – 公司理財 – 政府財務 – 商人銀行 – 諮詢服務 Sales & trading( 財務交易與銷售 ) – 銷售 – 報價 – 部位持有 – 財務 Retail banking( 消費金融 ) – 消費銀行 – 私人銀行 – 卡片服務 Commercial banking( 商業金融 ) – 商業銀行 e.g. 貸款保證專案融資 Payment & settlement( 收付清算 ) – 外部客戶服務 Agency services & Custody ( 代理業務 ) – 保管 – 代理 – 信託 Asset management( 資產管理 ) – 全權委託資金管理 – 非全權委託資金管理 Retail brokerage( 消費經紀 ) – 零售經紀
Business line / event types classification BUSI- NESS UNITS Level 1 Business Lines Internal Fraud External Fraud Employment Practice & Workplace Safety Clients, Products & Business Practices Damage to Physical Assets Business Disruption & System Failures Execution, Delivery & Process Mgt.** Invest- ment Banking Corporate Finance* Trading & Sales BankingRetail Banking Commercial Banking Payment & Settlement Agency Services & Custody OthersAsset Mgt.** Retail Brokerage Including Municipal/Gov’t Finance and merchant banking. ** Mgt. = management Resources: Basel Committee on Banking Supervision, “Working Paper on Regulatory Treatment of Operational Risk,” September 2001.www.bis.org Joint Combination Internal fraud( 內部詐欺 ) – 至少有一名公司內部人員參與，意圖詐 取、侵占公司財產、規避法令或公司內 部規範所導致的損失。 –e.g. 匿報交易 / 挪用公款 / 盜取盜用資產 External fraud( 外部詐欺 ) – 外部人員意圖詐取、侵占公司財產、規 避法令或公司內部規範所導致的損失。 –e.g. 偽造 / 駭客攻擊 Employment Practice & Workplace Safety ( 員工作業、工作場所安全 ) – 因違反雇用、健康或安全規定及協議、 支付個人損害求償或差異性 / 歧視事件所 導致的損失。 –e.g. 薪資 / 福利 / 所有歧視行為 Clients, Products & Business Practices ( 客戶、產品、營運慣例 ) – 非故意或疏忽而對特定客戶未盡專業義 務、或因產品特性及設計所導致之損失。 –e.g. 強制性行銷 / 產品瑕疵 / 未依規對客戶 徵信 Damage to Physical Assets ( 人員或資產損失 ) – 因天然災害或其他事件所導致之實質資 產減損。 Business Disruption & System Failures ( 營運中斷與電腦當機 ) – 因營運中斷與電腦當機所導致之損失。 –e.g. 硬體 / 軟體 / 通訊 / 水電 Business Disruption & System Failures ( 執行運送及作業流程之管理 ) – 與交易對手或賣方交易之處理不當或過 程管理疏失所導致之損失。 –e.g. 錯帳 / 不精確的外部報告 / 與同業交易 處理不當 / 未經授權接觸資料
Pillar 1. (MRC) Minimum Required Capital Pillar 2. SupervisoryPillar 3. Disclosure The 2001 New Basel Accord (including Operational Risk) Definition of Operational RiskData Collection & Category Basic Indicator Approach (BIA) Advanced Measurement Approach (AMA) Standardized Approach (SDA) Capital charge for operational risk: -12% of MRC % of Gross income Structure of Basel Ⅱ for “OpRisk” Operational Risk in Basel Ⅱ
Structure of Basel Ⅱ for“OpRisk” 2001 Basel Ⅱ, and Implement at 2006 Operational Risk in Basel Ⅱ
Pillar 1. Basic Indicator Approach (BIA) Where ： K BIA = the capital charge for OpRisk under the BIA EI = the level of an exposure “indicator” for the whole institution, provisionally gross income α = a fixed percentage, set by the BIS, relating the industry-wide level of required capital to the industry-wide level of the gross income. Operational Risk in Basel Ⅱ
Little Discussion about “Indicator” The indicator serves as a proxy for the scale of business operations and thus the likely scale of operational risk exposure within each of these business lines. Indicator--Gross Income Net interest incomeNet non-interest income Fees & Commission Net P&L from financial operationOther income Operational Risk in Basel Ⅱ
Little Discussion about “ α ” Where MRC j : Minimum Regulatory Capital for bank j EI j : Exposure indicator(gross income) for bank j Capital charge for operational risk: -12%of MRC % of Gross income j :Bank α is estimated based on industry (Banking) data. Operational Risk in Basel Ⅱ
Pillar 1. Standardized Approach (SDA) Where ： K TSA = the capital charge under the SDA EI i = the level of an exposure “indicator” for each of the 8 business lines β i = a fixed percentage, set by the Committee, Operational Risk in Basel Ⅱ
Pillar 1. Standardized Approach (SDA) Resources: Basel Committee on Banking Supervision, “Working Paper on Regulatory Treatment of Operational Risk,” September 2001.www.bis.org Operational Risk in Basel Ⅱ
Little Discussion about “ β ” β is estimated based on industry (Banking) data. β The beta for bank for business line MRC The Minimum Required Capital for bank Business line weighting The weight of each business line i ’s size over total business lines’ size. j :Bank i : Business lines Capital charge for operational risk: -12%of MRC % of Gross income Operational Risk in Basel Ⅱ
An estimation result of β Analysis of QIS* data: the Standardized Approach (Based on 12% of Minimum Regulatory Capital) *QIS: Quantitative Impact Study Resources: Basel Committee on Banking Supervision, “Working Paper on Regulatory Treatment of Operational Risk,” September 2001.www.bis.org Operational Risk in Basel Ⅱ
Pillar 1. Advanced Measurement Approach (AMA) An internal operational risk system. Not a standard approach yet. Three broadly discussed approaches –Internal Measurement Approach (IMA) –Loss Distribution Approach (LDA) –Scorecard Approach (SA) Operational Risk in Basel Ⅱ
Qualifying criteria and the relationship between approaches Before adapting a new approach, you must fulfill some criteria. Standardized Approach (SDA) Advanced Measurement Approaches (AMA) Basic Indicator Approach (BIA) SimpleComplex Why do banks want to upgrade to “AMA” approach? Operational Risk in Basel Ⅱ
Ans: Incentive- from 12% to 8% 75% of the level of BIA and SDA IMA 75% x 12% =8% Capital charge for operational risk: -12%of MRC Operational Risk in Basel Ⅱ
Internal Measurement Approach (IMA) Banks estimate operational risk capital based on measures of expected operational risk losses. IMA assumes a fixed and stable relationship between expected losses (the mean of the loss distribution) and unexpected losses (the tail of the loss distribution). Operational Risk in Basel Ⅱ, AMA
Internal Measurement Approach (IMA) Industry-Wide OpRisk Loss Distribution 0 E(L) Expected loss U(L) Unexpected loss Losses Probability of loss γ Section1 Section2 Section3 γ: a factor which translates the expected loss (EL) into a capital charge. Operational Risk in Basel Ⅱ, AMA
1. Joint Combination : business line / loss type combination 2. PE: The probability that an loss event occurs over some future horizon 3. LGE: The loss given that an event 4. EI: a proxy for the size (or amount of risk) of each business line’s operational risk exposure. 5. i : bank i 6. K : capital charge for OpRisk in each joint combination How to measure EL(expected loss)? Question : Is “γ” applicable for each bank ? Operational Risk in Basel Ⅱ, AMA
-RPI captures the difference in the risk profile of an individual bank. Risk Profile Index (RPI) Industry Dustribution -- RPI = 1.0 Case 1: fatter tale -- RPI > 1.0 Case 1: less fat tale -- RPI > 1.0
Loss Distribution Approach (LDA) Under LDA, banks estimate, for each business line/loss type combination, the likely distribution of operational risk losses over future horizon (for instance, one year). The capital charge is based on the simple sum of the VaR for each business line (and loss type ). Operational Risk in Basel Ⅱ, AMA
Scorecard Approach (SA) An initial level of operational risk capital at the firm or business line level Modify these amounts over time on the basis of scorecards that attempt to capture the underlying risk profile and risk control environment of the various business lines. SA can reflect improvements in the risk control environment that will reduce both the frequency and severity of future operational risk losses. Operational Risk in Basel Ⅱ, AMA
The “floor” The committee will limit the reduction in capital held when a bank moves from SDA approach to IMA approach by setting a floor, below which the required capital cannot fall.
Pillar 2 : Supervisory Review Process Pillar 2 applies to all risks that a bank is facing. Four principles : –Principal 1 : A bank should build systems to identify, measure, monitor and control its risks and maintain capital accordingly. –Principles 2-4 : supervisors should assess the internal capital adequacy assessments and strategies in place and require remedial actions where these are inadequate. Operational Risk in Basel Ⅱ
Pillar 3. Disclosure Resources: Basel Committee on Banking Supervision, “Working Paper on Regulatory Treatment of Operational Risk,” September 2001.www.bis.org Opposition to publication of operational data. Operational Risk in Basel Ⅱ
Part II Operational Risk in Basel Ⅱ Part III Operational Risk Management In Practice Part I The Introduction to Operational Risk I n d e x
THE 10 PRINCIPLE BIS published “Sound Practices for the Management and Supervision of Operational Risk” on February 2003 The document –Outlines a set of principles that provide a framework for the effective management and supervision of operational risk. –For use by banks and supervisory authorities when evaluating operational risk management policies and practices.
THE 10 PRINCIPLE Developing An Risk Management Environment Principle 1: Operational risks is a distinct risk category that should be managed. Principle 2: The bank’s operational risk management framework is subject to effective and comprehensive internal audit. Principle 3:The framework should be consistently implemented throughout the whole banking organization
THE 10 PRINCIPLE Risk Management Principle 4: Banks should identify and assess the operational risk inherent in all material products, activities, processes and systems. Principle 5: Banks should implement a process to regularly monitor operational risk profiles and material exposures to losses. Principle 6: Banks should have policies, processes and procedures to control and/or mitigate material operational risks. Principle 7: Banks should have in place contingency and business continuity plans.
THE 10 PRINCIPLE Role of Supervisors Principle 8: Banking supervisors should require that all banks have an effective risk management framework. Principle 9:Supervisors should conduct regular evaluation of a bank’s operational risk management.
THE 10 PRINCIPLE Role of Disclosure Principle 10: Banks should make sufficient public disclosure to allow market participants to assess their approach to operational risk management.
Rethink Operational Risk Currently the industry seem to be working by analogy to market risk and credit risk,but… Market & credit risks: –Are accepted knowingly as part of the business decision. –Have a quantifiable size - Money lent,currency size, etc. –Have a reasonable amount of homogeneity –Have solid, long term historical data –Exhibit statistical properties that appear to be somewhat stable across time Does operational risk exhibit any of these qualities? Source:Credit Suisse Group Report
Rethink Operational Risk Operational Risks exhibit numerous difficult properties: Risks implicitly accepted as part of being in business –Risks rarely chosen explicitly Risks are diverse by nature –It’s an all other category –Is there a link between customer lawsuits, rogue traders and operations fails? Risks are highly context dependent & change rapidly –Are your business, people or processing systems similar to 10 years ago? –Are the threats to those systems similar to 10 years ago? –How do you know when risks change (other than by judgment) –Is your estimate for Op Risk the same as pre 9/11? Source:Credit Suisse Group Report
Rethink Operational Risk Data Problem: Source:Credit Suisse Group Report
Rethink Operational Risk Control accidents can be separated into two types: Individual, high frequency events can be better understood and controlled through more quantitative techniques –Relatively high frequency; can develop fairly robust statistics –Quantification and measurement can provide some valuable management tools Organizational accidents are difficult events to understand and control –Occur infrequently & are hard to predict or foresee –Normally variety of contributing factors combine to cause the loss –Each has its own individual pattern of cause and effect Source:Credit Suisse Group Report
Rethink Operational Risk Operational Risk is a different animal and has to be treated differently Quantification Strategy Prevention Strategy Risk Mitigation Strategy
Quantification Strategy Role for OpRisk Quantification Enables measurement of capital based on historical experience of firm Improves bank decision making Provides a mechanism for better understanding “tail events,” those that may be outside a bank’s historical experience. Provides method for measuring the effect of risk mitigation tools.
Quantification Strategy Example:From Risk Information to Risk Capital Source:Allianz Report
Quantification Strategy What (Loss describing) Data to collect? Knowledge System Data Pool Source:Allianz Report
Risk Mitigation Strategy Purpose of Risk Mitigation Reducing loss when accidents happen Tools for Risk Mitigation Securitizaion Insurance Business Continuity Plan
Risk Mitigation Strategy Risk Securitizaion:example In 1998 Toyota* entered into a relationship with Gramercy Place Insurance Ltd as the special purpose vehicle for this transaction. Securitized a portion of Toyota’s auto lease residual risk for 1999,2000, and 2001 to protect against high losses on vehicles returned to Toyota at the end of full-term leases.lease residual A deductible totaling up to the first 9% of residual value will be paid by Toyota on resulting losses. Losses that exceed the deductible are split 90% / 10% between investors and Toyota,respectively. Notes issued in classes rated Aa2 / AA and Ba2/BB Source:Goldman Sachs Report
Risk Mitigation Strategy Insurance seems to be the feasible tool at this moment Quantification techniques can provide firms with the framework to determine appropriate insurance coverage. Related insurances include: –Directors & Officers Liability –Professional Liability –Assets Insurance –Etc…
Risk Mitigation Strategy Insurance and Basel II Reduced overall level of the operational risk capital charge partly to recognize the risk- mitigating effects of insurance. If explicit recognition of “robust and comprehensive insurance” is permitted, it should be limited to AMA. There should be a limit on the overall impact of insurance risk mitigation on the final capital amount. Source :September 2001, Basel Committee on Banking Supervision, “Working Paper on the Regulatory Treatment of Operational Risk”
Risk Mitigation Strategy Insurance for Operational Risk: Example A number of shareholder class action suits are brought against a large commercial bank.Complaints assert that the bank engaged in numerous unlawful practices in order to increase profits, that the bank’s earnings had been overstated and were not prepared in accordance with GAAP, and that the bank failed to disclose a number of material events. INSURANCE:Combined D&O, BPL, Pension Trust Liability, and Bond and Computer Crime policies. SOLUTION:Combined suits were settled for $45 MM (excluding defense costs). The bank contributed the first $10 MM (policy deductible). Insurance paid the remaining $39MM. Source:Marsh & McLennan Companies Report
Risk Mitigation Strategy Business Continuity Plans What is “BC Plan”? Advance arrangements and procedures that enable an organization to respond to an event in such a manner that critical business functions continue with planned levels of interruption or essential change. The importance of BC Plan: According to Gartner Group survey, of the businesses that suffer a disaster and do not have a BC plan in place, 40% will fail within 18 months.
Risk Mitigation Strategy The Six Steps To Effective BC Planning perform a Business Impact Analysis (BIA) regular practice runs should be carried out at what point should the plan be invoked? strict guidelines to follow after the invocation Location, location, location People element Source :SunGard Availability Services Report
What is a lease residual? Residual is the dollar amount that the bank guarantees your new car will be worth at the end of the lease as long as you stay within the terms of the lease. At the end of the lease this is also the amount you would pay for the car if you wanted to purchase it, plus tax, license, doc & any other applicable fees. The residual is set by the bank and is a percentage of MSRP regardless of what the actual purchase price is. Residual is not negotiable as the bank is guaranteeing the value and therefore they set it. If at the end of the lease, you have stayed within the terms of the lease, if the car is worth more than the residual, you might want to buy it, sell it or trade it in. If however at lease end the value is less than the residual, you can give it back to the bank and not be responsible for anything (As long as you have stayed within the terms of the lease). Risk Mitigation Strategy