Financial Risk Management – Global Practice Analysis Report

Survey participants indicated they are involved in the daily practice of financial risk management as financial risk managers, in supervisory roles, as consultants, academics and trainers, auditors and regulators. They self-identified as highly educated — 71 percent hold a Master’s degree or higher. While 61 percent of respondents had more than five year’s experience in the financial services industry, less than half — 41 percent — had more than five year’s experience in financial risk management. This indicates that experienced financial services professionals enter the field of risk management from other areas of responsibility at financial institutions.

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More than 40 percent of respondents worked at banks, with consulting and asset management firms employing 17 and 16 percent, respectively. Approximately one-third of respondents hold the title of risk manager, one-quarter are analysts and 11 percent are consultants. Approximately 61 percent are employed at firms with more than 1,000 employees.

The GARP Global Practice Analysis survey addressed 49 specific tasks across six process-based domains. Respondents were asked to assign an importance rating from 1 (not important) to 4 (extremely important) to each task. Significantly, all 49 tasks were found to be important on the 4-point Importance Scale, meeting the industry best-practices threshold of 2.5 out of 4. Forty-seven of the 49 tasks received a mean importance rating of at least 3.0, indicating that these tasks are considered of moderate to high importance to the work of financial risk managers.

The top five tasks identified by respondents as most important, earning a mean importance rating of at least 3.3 among all survey respondents, are to:

  1. Identify signs of potential risk based on exposure, trends, monitoring systems regulatory and environmental change, organizational culture and behavior.
  2. Analyze and assess underlying risk drivers and risk interconnections.
  3. Communicate with relevant business stakeholders.
  4. Monitor risk exposure in comparison to limits and tolerances.
  5. Evaluate materiality of risk and impact on business.

The five tasks identified as least important, with a mean importance rating of or below 3.0 among all respondents, are:

  1. Create and inventory of models.
  2. Generate, validate, and communicate standardized risk reports for external purposes.
  3. Develop transparent model documentation for independent replication/validation.
  4. Set capital allocations and risk budgets in accordance with risk management framework.
  5. Recommend policy revisions as necessary.

Respondents were asked to identify at what level of experience each task should be part of the financial risk manager’s profile, according to a five-level Experience Scale:

  • Not necessary
  • Less than 2 years
  • 2 to 5 years
  • 6 to 10 years
  • More than 10 years

One-half of respondents indicated that financial risk managers should be able to perform all 49 tasks within the first five years of practice.

More than 77 percent of respondents said financial risk managers should be able to perform these specific tasks within their first five years of practice in financial risk management:

  • Monitor risk exposure in comparison to limits and tolerances
  • Define and determine type of risk (e.g., credit, market, operational) by classifying risk factors using a consistent risk taxonomy
  • Gather quantitative data to perform model evaluation
  • Select monitoring methods and set frequency (e.g., intra-daily, daily, weekly, monthly)
  • Gather qualitative information to perform model evaluation
  • Generate, validate, and communicate standardized risk reports for internal purposes (e.g., staff, executive management, board of directors)
  • Identify risk owners
  • Investigate why limits are exceeded by performing root-cause analysis
  • Analyze and assess underlying risk drivers and risk interconnections
  • Escalate breach when limits or alert levels are exceeded according to risk management plan/policies/strategies
  • Generate, validate, and communicate ad hoc reports to meet specific requirements
  • Escalate unusual behavior or potential risks according to risk management plan/ policies/strategies

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Financial risk managers are vital to any integrated financial system of managing and communicating risk. The GPA study is a contemporary and comprehensive description of the work of risk managers across work settings, geographic regions, job roles and experience levels.

The process of a practice analysis is important for programs that desire to continually evolve and reflect the critical knowledge and tasks in the industry. It is important for practitioners who desire to evolve and be successful in their career.

Click here to access GARP’s detailed survey report

 

Banks sailing in uncertain waters

The decision-making process apparent paradox

Corporate decision-making processes are driven by seemingly opposing forces.

On the  one hand, the human urge to dispose of instruments emerges in order

  • to understand context, specific self-direction
  • and to implement the actions required for following the plotted course.

On the other hand, the exhortation to keep the mind open

  • to an array of possible future scenarios,
  • to imagine and grasp the implications of the various possible trajectories,
  • to plot alternative courses according to the obstacles and opportunities encountered, that could lead to landing places other than those contemplated originally.

Needs that are intertwined as never before whenever the decision-maker operates in an area such as the banking sector, that is characterised by extremely pervasive regulatory requirements concerning the

  • maintenance and use of capital,
  • liquidity management,
  • checks on lending and distribution policies,

and that is structurally exposed to the volatility of the macroeconomic context and financial markets, greatly increasing the range of possible scenarios.

Thus, it is far from surprising or infrequent that one of the most common questions that CEOs ask the technical structures responsible for budgeting and risk planning is: ‘what if’? (‘what would happen if…?’). The problem is that, in the last few years, the ‘ifs’ at hand have rapidly multiplied, as there has been an exponential increase in the controlling variables for which feedback is required:

  • Net Interest Income (NII);
  • Cost Income ratio (C/I);
  • Return On Equity (ROE);
  • Non Performing Exposure (NPE) Ratio;
  • Liquidity Coverage Ratio (LCR);
  • Expected Credit Loss (ECL);
  • Common Equity Tier 1 (CET1) ratio,

to cite but a few among the most widespread. Planning has turned into an interdisciplinary and convoluted exercise, an issue hard to solve for CFOs and CROs in particular (naturally, should they not operate in close cooperation).

This greater complexity can result in the progressive loss of quality of the banks’ decision-making process, more often than not based on an incomplete information framework, whenever some controlling variables are unavailable, or even incorrect when there is an actual lack of information, specialist expertise and/or the instruments required for the modelling of events.

Partial mitigating circumstances include the fact that such events, aside from being numerous, are interdependent in their impact on the bank’s results and are particularly heterogeneous. These can in fact be exogenous (turbulence and interference along the way) or endogenous (the actions that the helmsman and the crew implement during navigation).

In the first case, these events are beyond the control of those responsible for the decision-making process, determined by the evolution of the market conditions and/or the choices of institutional subjects. As such, they are often hard to predict in their likelihood of occurrence, intensity, timing and duration. By nature, such phenomena are characterised by complex interactions, that make it crucial, albeit arduous, to comprehend the cause-effect mechanisms governing them. Lastly, their relevance is not absolute, but relative, in that it depends on the degree of reactivity of the bank’s business model and budgetary structure to the single risk factors to which the market value of the banks’ assets is exposed.

Conversely, in the case of endogenous events, uncertainty is more correlated to the ability of the bank’s top management

  • to quantify the level of ambition of the business actions,
  • to assess their multiple implications,
  • and specifically, to the bank’s actual ability to implement them within requested time frames and terms.

The taxonomy of banking strategic planning

Although these complexities are increasingly obvious, many banks still remain convinced about getting started on their respective courses with certainty, exposing themselves to a range of risks that can restrict or irreversibly compromise the efficacy of the decision-making processes. Some institutions are indeed persuaded that an ‘expert-based’ approach that has always characterised their planning methodologies shall continue to be sufficient and appropriate for steering the bank, also in future.

History teaches us that things have not always worked out that way. These actors have yet to understand that it has now become vital to foster the evolution of the planning process towards a model relying upon analytical methodologies and highly sophisticated and technological instruments (risk management, econometrics, statistics, financial engineering, …), making them available to those that have always considered experience, business knowledge and budgetary dynamics to be privileged instruments for making decisions.

Second mistake: many banks believe the uncertainty analysis to be wasteful and redundant for the purposes of planning since, ultimately, the allocation of objectives is (and will remain) based on assumptions and uniquely identified scenarios. In this case, the risk lies in failing to understand that, in actual fact, a broader analysis of possible scenarios contributes to better delineating the assigned objectives, by separating the external conditions from the contribution provided by internal actions. Moreover, testing various hypotheses and combinations of cases makes it easier to calibrate the ‘level of managerial ambition’, in line with the actual potential of the organisational structure and with the full involvement of the business functions responsible for attaining the corporate objectives.

The intersection of these two misreadings of the context results in a different positioning of the bank, with the relative risks and opportunities.

Models

ILLUMINATED

The planning process is built upon analytical data and models developed with the contribution of subject matter experts of different origins, which allows to consider the impacts of a specific scenario on the bank’s budget simultaneously and coherently. Nevertheless, not only does it improve the planning of a specific item, but it disposes of appropriate instruments to switch to a multi-scenario perspective and investigate the relevant scenarios for management, appraising the volatility regarding the expected results. This transition is extremely delicate: it entails a change in the way prospective information is produced by the technical functions and subsequently channelled to the top management and board of directors. In this context, the bank is governed via the analysis of deterministic scenarios and the statistical analysis of the probability distributions of the variables of interest. Leveraging this set of information (much more abundant and articulated than the traditional one) targets, risk propensity levels and relative alert and tolerance thresholds are established; business owners are provided not only with the final objectives, but also with details concerning the key risk factors (endogenous and exogenous alike) that might represent critical or success factors and the respective probabilities of occurrence.

DELUDED

The budget planning process is characterised by the prevalence of an expert-based approach (with a limited capacity of integrating quantitative models and methodologies, in that not always all budget items are developed by relying on the necessary instruments and expertise) and aimed at forecasting a single baseline scenario (the one under which the budget objectives are to be formalised, then articulated on the organisational units and business combinations).

ENLIGHTENED

The budgetary planning process is very accurate and incorporates specialist expertise (often cross-functional) required to understand and transmit the interactions across the managerial phenomena so as to ensure a full grasp of the bank’s ongoing context. The onus is chiefly on the ability to explain the phenomena inside the bank without prejudice to the external baseline scenario, that is ‘given’ by definition.

MISSING

The planning process attempts to consider the impact of alternative scenarios as compared to the baseline scenario, however, it is implemented on the basis of imprecise or incomplete modelling, in that developed without the analytical foundations and instruments required to appraise the consistency and the degree of likelihood of these scenarios, useful tools to sustain such a serious consideration. The focus remains on the comparison across the results produced under diverse conditions, while taking into account the approximations used.

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Achieving Optimal IFRS 9 Compliance

IFRS 9 will have a substantial financial impact on banks and create implementation challenges. By taking an optimal approach to compliance, banks can balance the financial impact and the effort required and still ensure compliance. To achieve this goal, banks will need significant support from technology. In this paper, we explore the software functionality needed to support optimal IFRS 9 compliance for banks.

Across the globe, large financial institutions are working to understand the implications of the latest impairment requirements introduced by IASB1 as part of the IFRS 9 package. According to a recent Deloitte industry survey, this single, forward-looking “expected loss” impairment standard will have a significant financial impact for the majority of large banks.

Given that IFRS 9 requirements will be effective Jan. 1, 2018, banks are beginning to pay greater attention to this new accounting standard; IFRS 9 implementation budgets doubled during the last 12 months. But as discussed in this paper, any steps they take toward IFRS 9 compliance should not be taken in isolation, but rather in the context of existing regulatory pressures. With Basel III, CCAR, stress testing, BCBS 239 and other requirements, banks are already exposed to high levels of regulatory scrutiny and devoting substantial attention to compliance efforts.

Finally, it is expected that key jurisdictions will implement similar impairment approaches to IFRS 9, with the most relevant being the FASB’s Current Expected Credit Loss project. These initiatives will combine to broaden the scope of banks that need to implement ECL-based impairment approaches.

ifrs9

Click here to access SAS’ detailed analysis.