1. CLEAR 2008 Annual Conference Anchorage, Alaska Consistent Decision Making Robert Chambers AssetRisk Advisory Inc.

2. CLEAR 2008 Annual Conference Anchorage, Alaska Meaning of Consistency

3. CLEAR 2008 Annual Conference Anchorage, Alaska Importance of Consistency Strategy implementation Effectiveness Fairness

4. CLEAR 2008 Annual Conference Anchorage, Alaska Judgment This presentation is concerned with decisions where judgment (or discretion) is required. Not all decisions by a regulator require judgment. The goal is to guide administrative discretion.

5. CLEAR 2008 Annual Conference Anchorage, Alaska Major Causes of Inconsistency Insufficient focus on what is important. Silos that exist within the regulator. Ineffective and out-of-date processes. Inadequate training. Overconfident licensee committees (self regulation).

6. CLEAR 2008 Annual Conference Anchorage, Alaska Indicators of Inconsistency Unpredictable outcomes. Overturned decisions. Allegations of unfairness. Non-transparent processes. Excessive criticism by the media. Tolerance of the ‘likeable rogue’.

7. CLEAR 2008 Annual Conference Anchorage, Alaska Top-Down Implementation

8. CLEAR 2008 Annual Conference Anchorage, Alaska Intended Outcomes The definition of intended outcomes requires thought and planning before processes are designed to guide decision making.

9. CLEAR 2008 Annual Conference Anchorage, Alaska Tools that Aid Consistency Testing using control groups. Risk prioritization worksheets. Case assessment worksheets. Decision trees. Sound, documented processes. Training. Case management systems.

10. CLEAR 2008 Annual Conference Anchorage, Alaska Modeling Lack of reliable historical data is a problem in developing decision trees that rely on algorithms. ‘Washing’ of historical data can be cost prohibitive and sometimes impossible if all relevant information was not collected originally.

11. CLEAR 2008 Annual Conference Anchorage, Alaska Ongoing Monitoring Management oversight by capable professionals who have bought into the process. Periodic independent reviews of process and outcomes.

12. CLEAR 2008 Annual Conference Anchorage, Alaska Case Study The concern. The response.

13. CLEAR 2008 Annual Conference Anchorage, Alaska Case – Regulatory Focus

14. CLEAR 2008 Annual Conference Anchorage, Alaska Case – Prioritization of Risks 1.Sample worksheet tool ‘A’. 2.Determine responsibility for control. 3.Likelihood. 4.Impact.

15. CLEAR 2008 Annual Conference Anchorage, Alaska Case – Complaint Assessment 1.Sample worksheet tool ‘B’. 2.Evaluate every complaint/referral for regulatory significance. 3.Factors – plus and minus. 4.Quantitative vs. non-quantitative analysis. 5.Assess priority and resource allocation.

16. CLEAR 2008 Annual Conference Anchorage, Alaska Conclusion Once consistency has been achieved within regulators, the next goal will be increasing consistency among regulators.

17. CLEAR 2008 Annual Conference Anchorage, Alaska Contact Robert Chambers, LL.B., CPA, FCA AssetRisk Advisory Inc. 1402-30 Wellington Street East Toronto, Canada M5E 1S3 Direct (416) 304-0068 robert.chambers@assetrisk.ca