An Animal Kingdom Of Disruptive Risks -How boards can oversee black swans, gray rhinos, and white elephants

Publié le par hanswillertbleuazurconsultingeu

Where was the board? As a corporate director, imagine you find yourself in one of these difficult situations:

  • Unexpected financial losses mount as your bank faces a sudden collapse during a 1-in-100-year economic crisis.
  • Customers leave and profits drop year after year as a new technology start-up takes over your No. 1 market position.
  • Negative headlines and regulatory actions besiege your company following undesirable tweets and other belligerent behavior from the CEO.

These scenarios are not hard to imagine when you consider what unfolded before the boards of Lehman Brothers, Blockbuster, Tesla, and others. In the context of disruptive risks, these events can be referred to as black swans, gray rhinos, and white elephants, respectively. While each has unique characteristics, the commonality is that all of these risks can have a major impact on a company’s profitability, competitive position, and reputation.

In a VUCA (volatile, uncertain, complex, and ambiguous) world, boards need to expand their risk governance and oversight to include disruptive risks. This article addresses three fundamental questions:

  • What are black swans, gray rhinos, and white elephants?
  • Why are they so complex and difficult to deal with?
  • How should directors incorporate these disruptive risks as part of their oversight?

Why are companies so ill prepared for disruptive risks? There are three main challenges:

  1. standard enterprise risk management (ERM) programs may not capture them;
  2. they each present unique characteristics and complexities;
  3. and cognitive biases prevent directors and executives from addressing them.

Standard tools used in ERM, including risk assessments and heat maps, are not timely or dynamic enough to capture unconventional and atypical risks. Most risk quantification models—such as earnings volatility and value-at-risk models—measure potential loss within a 95 percent or 99 percent confidence level. Black swan events, on the other hand, may have a much smaller than 0.1 percent chance of happening. Gray rhinos and white elephants are atypical risks that may have no historical precedent or operational playbooks. As such, disruptive risks may not be adequately addressed in standard ERM programs even if they have the potential to destroy the company. The characteristics and complexities of each type of disruptive risk are unique. The key challenge with black swans is prediction. They are outliers that were previously unthinkable. That is not the case with gray rhinos, since they are generally observable trends. With gray rhinos the main culprit is inertia: companies see the megatrends charging at them, but they can’t seem to mitigate the risk or seize the opportunity. The key issue with white elephants is subjectivity. These no-win situations are often highly charged with emotions and conflicts. Doing nothing is usually the easiest choice but leads to the worst possible outcome. While it is imperative to respond to disruptive risks, cognitive biases can lead to systematic errors in decision making. Behavioral economists have identified dozens of biases, but several are especially pertinent in dealing with disruptive risks:

  • Availability and hindsight bias is the underestimation of risks that we have not experienced and the overestimation of risks that we have. This bias is a key barrier to acknowledging atypical risks until it is too late.
  • Optimism bias is a tendency to overestimate the likelihood of positive outcomes and to underestimate the likelihood of negative outcomes. This is a general issue for risk management, but it is especially problematic in navigating disruptive risks.
  • Confirmation bias is the preference for information that is consistent with one’s own beliefs. This behavior prevents us from processing new and contradictory information, or from responding to early signals.
  • Groupthink or herding occurs when individuals strive for group consensus at the cost of objective assessment of alternative viewpoints. This is related to the sense of safety in being part of a larger group, regardless if their actions are rational or not.
  • Myopia or short-termism is the tendency to have a narrow view of risks and a focus on short-term results (e.g., quarterly earnings), resulting in a reluctance to invest for the longer term.
  • Status quo bias is a preference to preserve the current state. This powerful bias creates inertia and stands in the way of appropriate actions.

To overcome cognitive biases, directors must recognize that they exist and consider how they impact decision making. Moreover,

  • board diversity,
  • objective data,
  • and access to independent experts

can counter cognitive biases in the boardroom.

Recommendations for Consideration

How should directors help their organizations navigate disruptive risks? They can start by asking the right questions in the context of the organization’s business model and strategy. The chart below lists 10 questions that directors can ask themselves and management.

NACD1

In addition, directors should consider the following five recommendations to enhance their risk governance and oversight:

  1. Incorporate disruptive risks into the board agenda. The full board should discuss the potential impact of disruptive risks as part of its review of the organization’s strategy to create sustainable long-term value. Disruptive risks may also appear on the agenda of key committees, including the risk committee’s assessment of enterprise risks, the audit committee’s review of risk disclosures, the compensation committee’s determination of executive incentive plans, and the governance committee’s processes for addressing undesirable executive behavior. The key is to explicitly incorporate disruptive risks into the board’s oversight and scope of work.
  2. Ensure that fundamental ERM practices are effective. Fundamental ERM practices—risk policy and analytics, management strategies, and metrics and reporting—provide the baseline from which disruptive risks can be considered. As an example, the definition of risk appetite can inform discussions of loss tolerance relative to disruptive risks. As an early step, the board should ensure that the overall ERM framework is robust and effective. Otherwise, the organization may fall victim to “managing risk by silo” and miss critical interdependencies between disruptive risks and other enterprise risks.
  3. Consider scenario planning and analysis. Directors should recognize that basic ERM tools may not fully capture disruptive risks. They should consider advocating for, and participating in, scenario planning and analysis. This is akin to tabletop exercises for cyber-risk events, except much broader in scope. Scenario analysis can be a valuable tool to help companies put a spotlight on hidden risks, generate strategic insights on performance drivers, and identify appropriate actions for disruptive trends. The objective is not to predict the future, but to identify the key assumptions and sensitivities in the company’s business model and strategy. In addition to scenario planning, dynamic simulation models and stress-testing exercises should be considered.
  4. Ensure board-level risk metrics and reports are effective. The quality of risk reports is key to the effectiveness of board risk oversight. Standard board risk reports often are comprised of insufficient information: historical loss and event data, qualitative risk assessments, and static heat maps. An effective board risk report should include quantitative analyses of risk impacts to earnings and value, key risk metrics measured against risk appetite, and forwardlooking information on emerging risks. By leveraging scenario planning, the following reporting components can enhance disruptive risk monitoring:
    • Market intelligence data that provides directors with useful “outside-in” information, including key business and industry developments, consumer and technology trends, competitive actions, and regulatory updates.
    • Enterprise performance and risk analysis including key performance and risk indicators that quantify the organization’s sensitivities to disruptive risks.
    • Geo-mapping that highlights global “hot spots” for economic, political, regulatory, and social instability. This can also show company-specific risks such as third-party vendor, supply chain, and cybersecurity issues.
    • Early-warning indicators that provide general or scenariospecific signals with respect to risk levels, effectiveness of controls, and external drivers.
    • Action triggers and plans to facilitate timely discussions and decisions in response to disruptive risks.
  5. Strengthen board culture and governance. To effectively oversee disruptive risks, the board must be fit for purpose. This requires creating a board culture that considers nontraditional views, questions key assumptions, and supports continuous improvement. Good governance practices should be in place in the event a white elephant appears. For example, what is the board protocol and playbook if the CEO acts inappropriately? In the United States, the 25th Amendment and impeachment clauses are in place ostensibly to remove a reprehensible president. Does the organization have procedures to remove a reprehensible CEO?

The following chart summarizes the key characteristics, examples, indicators, and strategies for identifying and addressing black swans, gray rhinos, and white elephants. The end goal should be to enhance oversight of disruptive risks and counter the specific challenges that are presented. To mitigate the unpredictability of black swans, the company should develop contingency plans with a focus on preparedness. To overcome inertia and deal with gray rhinos, the company needs to establish organizational processes and incentives to increase agility. To balance subjectivity and confront white elephants, directors should invest in good governance and objective input that will support decisiveness.

NACD2

The Opportunity for Boards

In a VUCA world, corporate directors must expand their traditional risk oversight beyond well-defined strategic, operational, and financial risks. They must consider atypical risks that are hard to predict, easy to ignore, and difficult to address. While black swans, gray rhinos, and white elephants may sound like exotic events, directors could enhance their recognization of them by reflecting on their own experiences serving on boards.

Given their experiences, directors should provide a leading voice to improve oversight of disruptive risks. They have a comparative advantage in seeing the big picture based on the nature of their work— part time, detached from day-to-day operations, and with experience gained from serving different companies and industries. Directors can add significant value by providing guidance to management and helping them see the forest for the trees. Finally, there is an opportunity side to risk. There are positive and negative black swans. A company can invest in the positive ones and be prepared for the negative ones. For every company that is trampled by a gray rhino, another company is riding it to a higher level of performance. By addressing the white elephant in the boardroom, a company can remediate an unspoken but serious problem. In the current environment, board oversight of disruptive risks represents both a risk management imperative and a strategic business opportunity.

Click here to access NACD’s summary

From Risk to Strategy : Embracing the Technology Shift

Publié le par hanswillertbleuazurconsultingeu

The role of the risk manager has always been to understand and manage threats to a given business. In theory, this involves a very broad mandate to capture all possible risks, both current and future. In practice, however, some risk managers are assigned to narrower, siloed roles, with tasks that can seem somewhat disconnected from key business objectives.

Amidst a changing risk landscape and increasing availability of technological tools that enable risk managers to do more, there is both a need and an opportunity to move toward that broader risk manager role. This need for change – not only in the risk manager’s role, but also in the broader approach to organizational risk management and technological change – is driven by five factors.

Marsh Ex 1

The rapid pace of change has many C-suite members questioning what will happen to their business models. Research shows that 73 percent of executives predict significant industry disruption in the next three years (up from 26 percent in 2018). In this challenging environment, risk managers have a great opportunity to demonstrate their relevance.

USING NEW TOOLS TO MANAGE RISKS

Emerging technologies present compelling opportunities for the field of risk management. As discussed in our 2017 report, the three levers of data, analytics, and processes allow risk professionals a framework to consider technology initiatives and their potential gains. Emerging tools can support risk managers in delivering a more dynamic, in-depth view of risks in addition to potential cost-savings.

However, this year’s survey shows that across Asia-Pacific, risk managers still feel they are severely lacking knowledge of emerging technologies across the business. Confidence scores were low in all but one category, risk management information systems (RMIS). These scores were only marginally higher for respondents in highly regulated industries (financial services and energy utilities), underscoring the need for further training across all industries.

Marsh Ex 3

When it comes to technology, risk managers should aim for “digital fluency”, a level of familiarity that allows them to

  • first determine how technologies can help address different risk areas,
  • and then understand the implications of doing so.

They need not understand the inner workings of various technologies, as their niche should remain aligned with their core expertise: applying risk technical skills, principles, and practices.

CULTIVATING A “DIGITAL-FIRST” MIND-SET

Successful technology adoption does not only present a technical skills challenge. If risk function digitalization is to be effective, risk managers must champion a cultural shift to a “digital-first” mindset across the organization, where all stakeholders develop a habit of thinking about how technology can be used for organizational benefit.

For example, the risk manager of the future will be looking to glean greater insights using increasingly advanced analytics capabilities. To do this, they will need to actively encourage their organization

  • to collect more data,
  • to use their data more effectively,
  • and to conduct more accurate and comprehensive analyses.

Underlying the risk manager’s digitalfirst mind-set will be three supporting mentalities:

1. The first of these is the perception of technology as an opportunity rather than a threat. Some understandable anxiety exists on this topic, since technology vendors often portray technology as a means of eliminating human input and labor. This framing neglects the gains in effectiveness and efficiency that allow risk managers to improve their judgment and decision making, and spend their time on more value-adding activities. In addition, the success of digital risk transformations will depend on the risk professionals who understand the tasks being digitalized; these professionals will need to be brought into the design and implementation process right from the start. After all, as the Japanese saying goes, “it is workers who give wisdom to the machines.” Fortunately, 87 percent of PARIMA surveyed members indicated that automating parts of the risk manager’s job to allow greater efficiency represents an opportunity for the risk function. Furthermore, 63 percent of respondents indicated that this was not merely a small opportunity, but a significant one (Exhibit 6). This positive outlook makes an even stronger statement than findings from an earlier global study in which 72 percent of employees said they see technology as a benefit to their work

2. The second supporting mentality will be a habit of looking for ways in which technology can be used for benefit across the organization, not just within the risk function but also in business processes and client solutions. Concretely, the risk manager can embody this culture by adopting a data-driven approach, whereby they consider:

  • How existing organizational data sources can be better leveraged for risk management
  • How new data sources – both internal and external – can be explored
  • How data accuracy and completeness can be improved

“Risk managers can also benefit from considering outside-the-box use cases, as well as keeping up with the technologies used by competitors,” adds Keith Xia, Chief Risk Officer of OneHealth Healthcare in China.

This is an illustrative rather than comprehensive list, as a data-driven approach – and more broadly, a digital mind-set – is fundamentally about a new way of thinking. If risk managers can grow accustomed to reflecting on technologies’ potential applications, they will be able to pre-emptively spot opportunities, as well as identify and resolve issues such as data gaps.

3. All of this will be complemented by a third mentality: the willingness to accept change, experiment, and learn, such as in testing new data collection and analysis methods. Propelled by cultural transformation and shifting mind-sets, risk managers will need to learn to feel comfortable with – and ultimately be in the driver’s seat for – the trial, error, and adjustment that accompanies digitalization.

MANAGING THE NEW RISKS FROM EMERGING TECHNOLOGIES

The same technological developments and tools that are enabling organizations to transform and advance are also introducing their own set of potential threats.

Our survey shows the PARIMA community is aware of this dynamic, with 96 percent of surveyed members expecting that emerging technologies will introduce some – if not substantial – new risks in the next five years.

The following exhibit gives a further breakdown of views from this 96 percent of respondents, and the perceived sufficiency of their existing frameworks. These risks are evolving in an environment where there are already questions about the relevance and sufficiency of risk identification frameworks. Risk management has become more challenging due to the added complexity from rapid shifts in technology, and individual teams are using risk taxonomies with inconsistent methodologies, which further highlight the challenges that risk managers face in managing their responses to new risk types.

Marsh Ex 9

To assess how new technology in any part of the organization might introduce new risks, consider the following checklist :

HIGH-LEVEL RISK CHECKLIST FOR EMERGING TECHNOLOGY

  1. Does the use of this technology cut across existing risk types (for example, AI risk presents a composite of technology risk, cyber risk, information security risk, and so on depending on the use case and application)? If so, has my organization designated this risk as a new, distinct category of risk with a clear definition and risk appetite?
  2. Is use of this technology aligned to my company’s strategic ambitions and risk appetite ? Are the cost and ease of implementation feasible given my company’s circumstances?
  3. Can this technology’s implications be sufficiently explained and understood within my company (e.g. what systems would rely on it)? Would our use of this technology make sense to a customer?
  4. Is there a clear view of how this technology will be supported and maintained internally, for example, with a digitally fluent workforce and designated second line owner for risks introduced by this technology (e.g. additional cyber risk)?
  5. Has my company considered the business continuity risks associated with this technology malfunctioning?
  6. Am I confident that there are minimal data quality or management risks? Do I have the high quality, large-scale data necessary for advanced analytics? Would customers perceive use of their data as reasonable, and will this data remain private, complete, and safe from cyberattacks?
  7. Am I aware of any potential knock-on effects or reputational risks – for example, through exposure to third (and fourth) parties that may not act in adherence to my values, or through invasive uses of private customer information?
  8. Does my organization understand all implications for accounting, tax, and any other financial reporting obligations?
  9. Are there any additional compliance or regulatory implications of using this technology? Do I need to engage with regulators or seek expert advice?
  10. For financial services companies: Could I explain any algorithms in use to a customer, and would they perceive them to be fair? Am I confident that this technology will not violate sanctions or support crime (for example, fraud, money laundering, terrorism finance)?

SECURING A MORE TECHNOLOGY-CONVERSANT RISK WORKFORCE

As risk managers focus on digitalizing their function, it is important that organizations support this with an equally deliberate approach to their people strategy. This is for two reasons, as Kate Bravery, Global Solutions Leader, Career at Mercer, explains: “First, each technological leap requires an equivalent revolution in talent; and second, talent typically becomes more important following disruption.”

While upskilling the current workforce is a positive step, as addressed before, organizations must also consider a more holistic talent management approach. Risk managers understand this imperative, with survey respondents indicating a strong desire to increase technology expertise in their function within the next five years.

Yet, little progress has been made in adding these skills to the risk function, with a significant gap persisting between aspirations and the reality on the ground. In both 2017 and 2019 surveys, the number of risk managers hoping to recruit technology experts has been at least 4.5 times the number of teams currently possessing those skills.

Marsh Ex 15

EMBEDDING RISK CULTURE THROUGHOUT THE ORGANIZATION

Our survey found that a lack of risk management thinking in other parts of the organization is the biggest barrier the risk function faces in working with other business units. This is a crucial and somewhat alarming finding – but new technologies may be able to help.

Marsh Ex 19

As technology allows for increasingly accurate, relevant, and holistic risk measures, organizations should find it easier to develop risk-based KPIs and incentives that can help employees throughout the business incorporate a risk-aware approach into their daily activities.

From an organizational perspective, a first step would be to describe risk limits and risk tolerance in a language that all stakeholders can relate to, such as potential losses. Organizations can then cascade these firm-wide risk concepts down to operational business units, translating risk language into tangible and relevant incentives that encourages behavior that is consistent with firm values. Research shows that employees in Asia want this linkage, citing a desire to better align their individual goals with business goals.

The question thus becomes how risk processes can be made an easy, intuitive part of employee routines. It is also important to consider KPIs for the risk team itself as a way of encouraging desirable behavior and further embedding a risk-aware culture. Already a majority of surveyed PARIMA members use some form of KPIs in their teams (81 percent), and the fact that reporting performance is the most popular service level measure supports the expectation that PARIMA members actively keep their organization informed.

Marsh Ex 21

At the same time, these survey responses also raise a number of questions. Forty percent of organizations indicate that they measure reporting performance, but far fewer are measuring accuracy (15 percent) or timeliness (16 percent) of risk analytics – which are necessary to achieve improved reporting performance. Moreover, the most-utilized KPIs in this year’s survey tended to be tangible measures around cost, from which it can be difficult to distinguish a mature risk function from a lucky one.

SUPPORTING TRANSFORMATIONAL CHANGE PROGRAMS

Even with a desire from individual risk managers to digitalize and complement organizational intentions, barriers still exist that can leave risk managers using basic tools. In 2017, cost and budgeting concerns were the single, standout barrier to risk function digitalization, chosen by 67 percent of respondents, well clear of second placed human capital concerns at 18 percent. This year’s survey responses were much closer, with a host of ongoing barriers, six of which were cited by more than 40 percent of respondents.

Marsh Ex 22

Implementing the nuts and bolts of digitalization will require a holistic transformation program to address all these barriers. That is not to say that initiatives must necessarily be massive in scale. In fact, well-designed initiatives targeting specific business problems can be a great way to demonstrate success that can then be replicated elsewhere to boost innovation.

Transformational change is inherently difficult, in particular where it spans both technological as well as people dimensions. Many large organizations have generally relied solely on IT teams for their “digital transformation” initiatives. This approach has had limited success, as such teams are usually designed to deliver very specific business functionalities, as opposed to leading change initiatives. If risk managers are to realize the benefits of such transformation, it is incumbent on them to take a more active role in influencing and leading transformation programs.

Click here to access Marsh’s and Parima’s detailed report

Optimizing Your GRC Technology Ecosystem

Publié le par hanswillertbleuazurconsultingeu

Most organizations rely on multiple technologies to manage GRC across the enterprise. Optimizing a GRC technology ecosystem aligned with a defined GRC process structure improves risk-informed business decisions and achievement of strategic business objectives. This illustration outlines ways to continuously optimize your GRC technology ecosystem for

  • greater process consistency
  • and development of actionable information.

An integrated GRC technology ecosystem built on common vocabulary, taxonomy and processes enables

  • more accurate and timely reporting,
  • increased reliability of achievement of objectives
  • and greater confidence in assurance with less burden on the business.

Here are just a few of the key benefits:

Process and Technology Alignment

  • Common methods for core tasks, uniform taxonomies, and consistent vocabulary for governance, risk management and compliance across the organization
  • Risk-based actions and controls that ensure timely responses to changed circumstances
  • Standardized GRC processes based on understanding where in the organization each defined process takes place and how data is used in managing risks and requirements
  • Connected technologies as necessary to gain a complete view of the management actions, controls and information needed by each user

Governance Systems to include:

  • Strategy / Performance
  • Board Management
  • Audit & Assurance Tools

Risk Systems to include:

  • Brand & Reputation
  • Finance / Treasury Risk
  • Information / IT Risk
  • External Risk Content
  • Third Party Risk

Compliance Systems to include:

  • Policies
  • Helpline / Hotline
  • Training
  • EHS (Environment Health and Safety)
  • Fraud / Corruption
  • Global Trade
  • Privacy
  • Regulatory Change
  • AML (Anti Money Laundering) / KYC (Know Your Customer)

Enabling Systems to include:

  • Data Visualization
  • Analytics
  • Business Intelligence
  • Predictive Tools
  • External Data Sources

Protective Systems to include:

  • Information Security
  • Data Protection
  • Assets Control

Benefits and Outcomes

  • Enhanced tracking of achievement of objectives and obstacles
  • Connected reporting for board/management/external stakeholders
  • Timely understanding of impact from operational decisions
  • Actionable view of changes needed to meet regulatory requirements
  • Clear action pathways for resolution of issues and process reviews
  • Consistent risk assessments feeding into advanced analytics
  • Improved predictive capabilities to support strategic planning
  • Control testing and audit trails for response to regulators and auditors
  • Greater confidence in assurance with less burden on the business
  • Enterprise-wide, departmental and geographic control standards

OCEG

Tips for Optimization

1. Process Framework

  • Identify tasks appropriate for standardization and schedule implementation across units
  • Assess vocabulary used throughout organization for inconsistencies and establish rules
  • Adjust process model periodically to continue alignment with business objectives and activities

2. Technology Ecosystem

  • Periodically review GRC technologies for gaps and duplication of systems
  • Assess appropriateness of connection of systems for data sharing and user access
  • Maintain a current road map for re-purposing and acquisition of technologies

3. Outcome Management

  • Apply standard processes for resolution of issues and remediation of identified process framework or technology ecosystem weaknesses
  • Enhance reporting capabilities with refined report structure and delivery methods/schedules
  • Ensure all users apply the process framework and understand how best to use the technology

Click here to access OCEG’s illustration in detail

Internal Audit’s Guide to Planning, Managing and Addressing Risks

Publié le par hanswillertbleuazurconsultingeu

As time passes and the modern-day enterprise evolves, so does the role of the internal auditor. What was once a function that was perceived as rule enforcers and compliance police is expanding into one that is a trusted advisor within the business. The last several years have introduced an enormous amount of change, but the proliferation of technology within the enterprise is accelerating every aspect; from operations to decision making.

The progressive steps organizations are taking as a result of the digital age present a bevy of benefits, but in turn, create a slew of challenges and risks. Subsequently, the internal audit function has been forced to adapt along the way, assuring key stakeholders in the business that risks have been identified, but above all, addressed and mitigated.

While identifying and managing risks tied to the business fall on management, it’s internal audit’s responsibility to focus on closing the loop. That’s why our second article focuses on the effective audit follow up, in addition to outlining the how and when tied to escalating risks.

A DYNAMIC AND ITERATIVE PROCESS

The COSO Internal Control – Integrated Framework (2013) provides that a “risk assessment involves a dynamic and iterative process for identifying and assessing risks to the achievement of objectives.” (emphasis added). To be effective, internal audit should be aware of and responsive to changes in known risks and additionally the emergence of new ones.

A purpose for the traditional (i.e., annual risk assessment) is to allow internal audit to develop a planning horizon which is understood by stakeholders and, in particular, executive management and the audit committee as a basis for the risks identified. In this process there can also be a push to finalize the internal audit “plan” so that budgets, schedules and staffing can be arranged.

With the emerging concept of “risk velocity”—measuring how fast a risk may affect an organization—is recognition that the typical risk assessment process is one that is not dynamic and iterative nor responsive to change in real time. Change does not occur on an annual basis. The move to a continuous and dynamic audit plan is significant for most internal audit departments. Some departments are already moving on this path and have had to adjust from a static process focused on listening to management on a seasonal basis to monitoring business objectives and risks that are rapidly changing.

Tony Redlinger, internal audit director with IHS Markit, observes the difficulties of the timely capture of risks as “asking the pertinent questions often without the broader knowledge of what the business is getting into, where the technology often advances much faster than the controls.”

BEYOND THE TYPICAL INTERNAL AUDIT RISK ASSESSMENT

What approaches internal audit functions can take to ramp up the process to achieve more dynamic audit planning?

One technique is to increase the frequency of the process and design a rolling service of assessments and audit planning. If existing processes can be made more streamlined and efficient, the time trajectory can be intensified to occur more frequently. Potentially, a concerted effort can result in an audit plan being updated every six months instead of annually. Since the risk identification process ideally is ongoing, management should be encouraged to implement a schedule to periodically review risks, while reserving the ability to accelerate reviews if a company objective changes, or risk factors increase.

For example, if management is considering an acquisition in a new jurisdiction, it could require the reevaluation of risk factors to determine how the decision could impact operations. Such processes can be formally linked into internal audit planning. Of course, existing sources of risk information should be identified and integrated into internal audit planning.

Other assessment processes including Enterprise Risk Management activities, department self-assessments and other functionspecific reviews in high-impact areas depending on industry (e.g., environmental hazards, cybersecurity threats, etc.), should connect and feed into internal audit processes.

Internal Audit 1

TECHNOLOGY TOOLS AND REALISM ABOUT SURVEYS

In the typical risk assessment, preparatory materials are provided and participants are asked a series of questions during sessions with audit staff. This process is expected to produce information to guide the allocation of resources and activities within internal audit so as to optimize the match between the company’s greatest risks and the corresponding mitigation efforts. The availability of sophisticated technology tools such as online surveys can seem to make it cheap and easy to gather voluminous data from a larger population, and to conduct statistical analysis of that data.

Dr. Hernan Murdock, vice president of the audit division at MISTI, finds surveys and questionnaires to be a technique to collect information. “[Questionnaires] promote risk and control awareness, while encouraging transparency and accountability,” he says.

Potentially, this means we can conduct a much larger assessment with the same resources. There is definitely a place for crowdsourcing risk as well as casting a wide net for particular fact patterns of concern, such as use of third-party sales intermediaries or collection of consumer personal data. Still, more data is not always better data. The essence of a good risk assessment is not popular opinion, mechanically sliced and diced; it is informed opinion and expert judgment applied to the facts. Be careful with gathering far more data than can be followed up on or that can be analyzed meaningfully which can result in human-judgment bottlenecks in the process.

Ordinarily, risk assessments gather information from senior executives and managers, as well as a sample of senior operational personnel in the business units. To the extent that “risk owners” are not in these groups, they are usually sought out, and sometimes manager-level input is also requested.

Front-line workers should be considered as well. It’s usually those who are in the details on a daily basis that have the best perspectives on risks and low-hanging fruit when it comes to increasing operational efficiency.

THE RISK OF THE INTERNAL AUDIT RISK ASSESSMENT

Here we are not talking about the risk assessment that drives the audit plan. Rather, this is the risk that the internal audit function itself will not achieve its objectives as a result of the risk assessment. Should you perform this type of quality engagement as well? See IIA’s Standards for the Professional Practice of Internal Auditing 2120—Risk Management: “The internal audit activity must evaluate the effectiveness and contribute to the improvement of risk management processes.”

The internal audit function in this regard should consider risks such as:

  • The potential that the audit risk assessment is inaccurate or incomplete leading to an ineffective audit plan
  • Audit staffing that is insufficient in terms of quality and capacity to deliver useful results on every engagement
  • Changes in business and risk not promptly identified so that the audit plan can be updated
  • Audit communications failing to provide information organizational stakeholders need, when they need it
  • Governance roles not able to understand audit results and their implications for management of the organization

Internal Audit 2

Beyond Quality: The Four-Part Approach for Audit Efficiency and Effectiveness

STEP 1: PLAN FOR ORGANIZATIONAL GROWTH

While the concept of quality is uniform for internal auditors of different varieties and capacities, effectiveness and efficiency can vary from organization to organization. Accordingly, clear definitions for these terms—the expectations for your team—must be established and adopted to plan for growth.

Use these questions as guidance when defining exactly what effectiveness and efficiency mean for you and your team:

  • Are we equipped with the up-to-date tools needed to conduct the best work possible?
  • Do we have the right resources and skill sets required to deliver our audit plan?
  • Are we contributing to organizational improvement? If so, can others see this?
  • Have we obtained any validation of our team’s quality, such as notification from managers or executives?
  • Is feedback effectively distributed to team members, so they know what areas to improve?
  • What quantifiable metrics can we associate with these definitions?

While you and your team’s definitions of effectiveness and efficiency are crucial, it is also important to gain the approval of key stakeholders involved in internal audit.

A major reason that process improvement initiatives fail, according to one Harvard Business Review article is that the people whose work will be directly impacted are often left out of the process.

Accordingly, feedback from stakeholders at the helm of the financial success of your company should also be incorporated. Here are a few stakeholders who should weigh in on your definitions of effectiveness and efficiency:

  1. Internal stakeholders: Board of directors, audit committee, executives, senior management and department leads
  2. External stakeholders: Regulators, standard-setters, vendors, customers and external audit teams

STEP 2: DO THE WORK NEEDED TO SET EXPECTATIONS

The second step of this process continues to articulate the definitions of effectiveness and efficiency, and sets expectations for your team.

By this stage, you should have an internal definition of effectiveness and efficiency, and you have tempered that definition in the context of what key internal and external stakeholders need. To better set your organization up for success, make these definitions more actionable and specific through the assignation of qualitative and quantitative metrics.

As described in a Forbes article, Forrester reports 74 percent of firms say they want to be “data-driven,” but only 29 percent are actually successful at connecting analytics to action. Actionable insights appear to be the missing link for companies that want
to drive business outcomes from their data.

Make these definitions more actionable and specific for your team by assigning qualitative and quantitative metrics for each. To collect qualitative and quantitative metrics, try the following tactics:

  • Look back at past performance data to determine quantitative metrics:
    • How many audits were scheduled?
    • How many were completed?
    • How was staff utilized?
    • What were the budgeted hours as compared to the actual hours?
  • Go on a listening tour of departments impacted by your work to determine qualitative metrics:
    • What do clients think of your team’s performance?
    • What do other internal stakeholders think of your team’s performance?
    • Do they consider you and your team leaders in their role or order-takers?
    • Would they want to engage in future projects with your team?

With these actionable definitions in hand, the expectations for your team should be crystal clear. It is ultimately up to chief audit executives to hold their teams accountable for efficient and effective—along with quality—work.

STEP 3: CHECK PROGRESS AGAINST SET EXPECTATIONS

To check the quality, effectiveness, and efficiency of your team’s work, internal audit leaders should look at individual performance on an ongoing basis—not just an annual one. After all, it is easier and less problematic for leaders to reevaluate individual performance in small increments before it becomes a major issue.

In organizations of all sizes, a traditional once-per-year approach to employee reviews is fading away in favor of more ongoing ones. As a Washington Post article describes, today’s employees have come to expect instant feedback in many other areas of their lives, and performance reviews should be the same. Besides, the article states, one report found that two-thirds of employees who receive the highest scores in a typical performance management system are not actually the organization’s highest performers.

Chief audit executives should encourage the completion of self-appraisals. A Harvard Business Review article explains that an effective self-appraisal should focus on what you have accomplished and talk about weaknesses carefully, using language with an emphasis on growth and improvement, rather than admonishment. Highlight your team’s blind spots that they might not be aware exists.

In short, employees want more frequent and iterative assessments of their work, and internal audit leaders need to step up to deliver this and ensure quality, effectiveness, and efficiency at all stages.

STEP 4: ACT UPON WHAT YOU HAVE LEARNED

By this step, internal audit leaders have an array of tools at their disposal, including:

  • Actionable definitions of effectiveness and efficiency for their teams
  • Qualitative and quantitative metrics to bolster these definitions
  • Information gathered from self- and manager-guided evaluations
  • An understanding of how team members have performed along these guidelines

With this information in hand, many opportunities for growth are apparent—simply compare where you want your team members to be against where they are right now. By
implementing these fact-based changes into your internal audit processes, leaders set the stage for cyclical organizational and personal improvement.

According to a survey, this type of continuous improvement yields a positive ROI for organizations, helping increase revenue, along with saving time and money—an average annual impact of $6,000. Additionally, these improvements are designed to compound with each cycle.

Just as the approach to monitoring and improving audit quality is ongoing and cyclical—there are always improvements yet to be made—this approach to improving effectiveness and efficiency is fluid as well.

By weaving this four-part process into the fabric of your internal audit methodology, leaders can improve effectiveness and efficiency in their organizations.

 

Click here to access Workiva’s and MISTI’s White Paper

Financial Risk Management – Global Practice Analysis Report

Publié le par hanswillertbleuazurconsultingeu

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.

GARP1

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

GARP2

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

 

Perspectives on the next wave of cyber

Publié le par hanswillertbleuazurconsultingeu

Financial institutions are acutely aware that cyber risk is one of the most significant perils they face and one of the most challenging to manage. The perceived intensity of the threats, and Board level concern about the effectiveness of defensive measures, ramp up continually as bad actors increase the sophistication, number, and frequency of their attacks.

Cyber risk management is high on or at the top of the agenda for financial institutions across the sector globally. Highly visible attacks of increasing insidiousness and sophistication are headline news on an almost daily basis. The line between criminal and political bad actors is increasingly blurred with each faction learning from the other. In addition, with cyberattack tools and techniques becoming more available via the dark web and other sources, the population of attackers continues to increase, with recent estimates putting the number of cyberattackers globally in the hundreds of thousands.

Cyber offenses against banks, clearers, insurers, and other major financial services sector participants will not abate any time soon. Looking at the velocity and frequency of attacks, the motivation for cyberattack upon financial services institutions can be several hundred times higher than for non-financial services organizations.

Observing these developments, regulators are prescribing increasingly stringent requirements for cyber risk management. New and emerging regulation will force changes on many fronts and will compel firms to demonstrate that they are taking cyber seriously in all that they do. However, compliance with these regulations will only be one step towards assuring effective governance and control of institutions’ Cyber Risk.

We explore the underlying challenges with regard to cyber risk management and analyze the nature of increasingly stringent regulatory demands. Putting these pieces together, we frame five strategic moves which we believe will enable businesses to satisfy business needs, their fiduciary responsibilities with regard to cyber risk, and regulatory requirements:

  1. Seek to quantify cyber risk in terms of capital and earnings at risk.
  2. Anchor all cyber risk governance through risk appetite.
  3. Ensure effectiveness of independent cyber risk oversight using specialized skills.
  4. Comprehensively map and test controls, especially for third-party interactions.
  5. Develop and exercise major incident management playbooks.

These points are consistent with global trends for cyber risk management. Further, we believe that our observations on industry challenges and the steps we recommend to address them are applicable across geographies, especially when considering prioritization of cyber risk investments.

FIVE STRATEGIC MOVES

The current environment poses major challenges for Boards and management. Leadership has to fully understand the cyber risk profile the organization faces to simultaneously protect the institution against everchanging threats and be on the front foot with regard to increasing regulatory pressures, while prioritizing the deployment of scarce resources. This is especially important given that regulation is still maturing and it is not yet clear how high the compliance bars will be set and what resources will need to be committed to achieve passing grades.

With this in mind, we propose five strategic moves which we believe, based on our experience, will help institutions position themselves well to address existing cyber risk management challenges.

1) Seek to quantify cyber risk in terms of capital and earnings at risk

Boards of Directors and all levels of management intuitively relate to risks that are quantified in economic terms. Explaining any type of risk, opportunity, or tradeoff relative to the bottom line brings sharper focus to the debate.

For all financial and many non-financial risks, institutions have developed methods for quantifying expected and unexpected losses in dollar terms that can readily be compared to earnings and capital. Further, regulators have expected this as a component of regulatory and economic capital, CCAR, and/or resolution and recovery planning. Predicting losses due to Cyber is particularly difficult because it consists of a combination of direct, indirect, and reputational elements which are not easy to quantify. In addition, there is limited historical cyber loss exposure data available to support robust cyber risk quantification.

Nevertheless, institutions still need to develop a view of their financial exposures of cyber risk with different levels of confidence and understand how this varies by business line, process, or platform. In some cases, these views may be more expert based, using scenario analysis approaches as opposed to raw statistical modeling outputs. The objectives are still the same – to challenge perspectives as to

  • how much risk exposure exists,
  • how it could manifest within the organization,
  • and how specific response strategies are reducing the institution’s inherent cyber risk.

2) Anchor all cyber risk governance through risk appetite

Regulators are specifically insisting on the establishment of a cyber risk strategy, which is typically shaped by a cyber risk appetite. This should represent an effective governance anchor to help address the Board’s concerns about whether appropriate risks are being considered and managed effectively.

Setting a risk appetite enables the Board and senior management to more deeply understand exposure to specific cyber risks, establish clarity on the Cyber imperatives for the organization, work out tradeoffs, and determine priorities.

Considering cyber risk in this way also enables it to be brought into a common framework with all other risks and provides a starting point to discuss whether the exposure is affordable (given capital and earnings) and strategically acceptable.

Cyber risk appetite should be cascaded down through the organization and provide a coherent management and monitoring framework consisting of

  • metrics,
  • assessments,
  • and practical tests or exercises

at multiple levels of granularity. Such cascading establishes a relatable chain of information at each management level across business lines and functions. Each management layer can hold the next layer more specifically accountable. Parallel business units and operations can have common standards for comparing results and sharing best practices.

Finally, Second and Third Line can have focal points to review and assure compliance. A risk appetite chain further provides a means for the attestation of the effectiveness of controls and adherence to governance directives and standards.

Where it can be demonstrated that risk appetite is being upheld to procedural levels, management will be more confident in providing the attestations that regulators require.

cyber1

3) Ensure effectiveness of independent cyber risk oversight using specialized skills

From our perspective, firms face challenges when attempting to practically fit cyber risk management into a “Three Lines of Defense” model and align cyber risk holistically within an enterprise risk management framework.

CROs and risk management functions have traditionally developed specialized skills for many risk types, but often have not evolved as much depth on IT and cyber risks. Organizations have overcome this challenge by weaving risk management into the IT organization as a First Line function.

In order to more clearly segregate the roles between IT, business, and Information Security (IS), the Chief Information Security Officer (CISO) and the IS team will typically need to be positioned as a « 1.5 Line of Defense » position. This allows an Information Security group to provide more formal oversight and guidance on the cyber requirements and to monitor day-today compliance across business and technology teams.

Further independent risk oversight and audit is clearly needed as part of the Third Line of Defense. Defining what oversight and audit means becomes more traceable and tractable when specific governance mandates and metrics from the Board down are established.

Institutions will also need to deal with the practical challenge of building and maintaining Cyber talent that can understand the business imperatives, compliance requirements, and associated cyber risk exposures.

At the leadership level, some organizations have introduced the concept of a Risk Technology Officer who interfaces with the CISO and is responsible for integration of cyber risk with operational risk.

4) Comprehensively map and test controls, especially for the third party interactions

Institutions need to undertake more rigorous and more frequent assessments of cyber risks across operations, technology, and people. These assessments need to test

  • the efficacy of surveillance,
  • the effectiveness of protection and defensive controls,
  • the responsiveness of the organization,
  • and the ability to recover

in a manner consistent with expectations of the Board.

Given the new and emerging regulatory requirements, firms will need to pay closer attention to the ongoing assessment and management of third parties. Third parties need to be tiered based on their access and interaction with the institution’s high value assets. Through this assessment of process, institutions need to obtain a more practical understanding of their ability to get early warning signals against cyber threats. In a number of cases, a firm may choose to outsource more IT or data services to third party providers (e.g., Cloud) where they consider that this option represents a more attractive and acceptable solution relative to the cost or talent demands associated with maintaining Information Security in-house for certain capabilities. At the same time, the risk of third party compromise needs to be fully understood with respect to the overall risk appetite.

cyber3

5) Develop and exercise incident management playbooks

A critical test of an institution’s cyber risk readiness is its ability to quickly and effectively respond when a cyberattack occurs.

As part of raising the bar on cyber resilience, institutions need to ensure that they have clearly documented and proven cyber incident response plans that include

  • a comprehensive array of attack scenarios,
  • clear identification of accountabilities across the organization,
  • response strategies,
  • and associated internal and external communication scenarios.

Institutions need to thoroughly test their incident response plan on an ongoing basis via table top exercises and practical drills. As part of a table top exercise, key stakeholders walk through specific attack scenarios to test their knowledge of response strategies. This exercise provides an avenue for exposing key stakeholders to more tangible aspects of cyber risk and their respective roles in the event of a cyberattack. It also can reveal gaps in specific response processes, roles, and communications that the institution will need to address.

Last but not least, incident management plans need to be reviewed and refined based on changes in the overall threat landscape and an assessment of the institution’s cyber threat profile; on a yearly or more frequent basis depending on the nature and volatility of the risk for a given business line or platform.

CONCLUSION

Cyber adversaries are increasingly sophisticated, innovative, organized, and relentless in developing new and nefarious ways to attack institutions. Cyber risk represents a relatively new class of risk which brings with it the need to grasp the often complex technological aspects, social engineering factors, and changing nature of Operational Risk as a consequence of cyber.

Leadership has to understand the threat landscape and be fully prepared to address the associated challenges. It would be impractical to have zero tolerance to cyber risk, so institutions will need to determine their risk appetite with regard to cyber, and consequently, make direct governance, investment, and operational design decisions.

The new and emerging regulations are a clear directive to financial institutions to keep cyber risk at the center of their enterprise-wide business strategy, raising the overall bar for cyber resilience. The associated directives and requirements across the many regulatory bodies represent a good and often strong basis for cyber management practices but each institution will need to further ensure that they are tackling cyber risk in a manner fully aligned with the risk management strategy and principles of their firm. In this context, we believe the five moves represent multiple strategically important advances almost all financial services firms will need to make to meet business security, resiliency, and regulatory requirements.

cyber2

click here to access mmc’s cyber handbook

 

 

Front Office Risk Management Technology

Publié le par hanswillertbleuazurconsultingeu

A complex tangle of embedded components

Over the past three decades, Front Office Risk Management (FORM) has developed in a piecemeal way. As a result of historical business drivers and the varying needs of teams focused on different products within banks, FORM systems were created for individual business silos, products and trading desks. Typically, different risk components and systems were entwined and embedded within trading systems and transaction processing platforms, and ran on different analytics, trade capture and data management technology. As a result, many banks now have multiple, varied and overlapping FORM systems.

Increasingly, however, FORM systems are emerging as a fully fledged risk solution category, rather than remaining as embedded components inside trading systems or transactional platforms (although those components still exist). For many institutions FORM, along with the frontoffice operating environment, has fundamentally changed following the global financial crisis of 2008. Banks are now dealing with a wider environment of systemically reduced profitability in which cluttered and inefficient operating models are no longer sustainable, and there are strong cost pressures for them to simplify their houses.

Equally, a more stringent and prescriptive regulatory environment is having significant direct and indirect impacts on front-office risk technology. Because of regulators’ intense scrutiny of banks’ capital management, the front office is continuously and far more acutely aware of its capital usage (and cost), and this is having a fundamental impact on the way the systems it uses are evolving. The imperative for risk-adjusted pricing means that traditional trading systems are struggling to cope with the growing importance of and demand for Valuation Adjustment (xVA) systems at scale. Meanwhile, regulations such as the Fundamental Review of the Trading Book (FRTB) will have profound implications for frontoffice risk systems.

As a result of these direct and indirect regulatory pressures, several factors are changing the frontoffice risk technology landscape:

  • The scale and complexity involved in data management.
  • Requirements for more computational power.
  • The imperative for integration and consistency with middle-office risk systems.

Evolving to survive

As banks recognize the need for change, FORM is slowly but steadily evolving. Banks can no longer put off upgrades to systems that were built for a different era, and consensus around the need for a flexible, cross-asset, externalized front-office risk system has emerged.

Over the past few years, most Tier 1 and Tier 2 banks have started working toward the difficult goal of

  • standardizing,
  • consolidating
  • and externalizing

their risk systems, extracting them from trading and transaction processing platforms (if that’s where they existed). These efforts are complicated by the nature of FORM – specifically that it cuts across several functional areas.

Vendors, meanwhile, are struggling with the challenges of meeting the often contradictory nature of front-office demands (such as the need for flexibility vs. scalability). As the frontoffice risk landscape shifts under the weight of all these demand-side changes, many leading vendors have been slow to adapt to the significant competitive challenges. Not only are they dealing with competition from new market entrants with different business models, in many instances they are also playing catch-up with more innovative Tier 1 banks. What’s more, the willingness to experiment and innovate with front-office risk systems is now filtering down to Tier 2s and smaller institutions across the board. Chartis is seeing an increase in ‘build and buy’ hybrid solutions that leverage open-source and open-HPC2 infrastructure.

The rapid development of new technologies is radically altering the dynamics of the market, following several developments:

  • A wave of new, more focused tools.
  • Platforms that leverage popular computational paradigms.
  • Software as a Service (SaaS) risk systems.

More often than not, incumbent vendors are failing to harness the opportunities that these technologies and new open-source languages bring, increasing the risk that they could become irrelevant within the FORM sector. Chartis contends that, as the market develops, the future landscape will be dominated by a combination of agile new entrants and existing players that can successfully transform their current offerings. Vendors have many different strategies in evidence, but the evolution required for them to survive and flourish has only just begun.

With that in mind, we have outlined several recommendations for vendors seeking to stay relevant in the new front-office risk environment:

  • Above all, focus on an open, flexible environment.
  • Create consistent risk data and risk factor frameworks.
  • Develop highly standardized interfaces.
  • Develop matrices and arrays as ‘first-class constructs’.
  • Embrace open-source languages and ecosystems.
  • Consider options such as partnerships and acquisitions to acquire the requisite new skills and technology capabilities in a relatively short period of time.

Chartis

Click here to access Chartis’ Vendor Spotlight Report

Failures and near misses in insurance – Overview of the causes and early identification

Publié le par hanswillertbleuazurconsultingeu

General approach

The approach to dealing with failures of financial institutions has witnessed significant changes since the eruption of the financial crisis in 2008, both from the crisis prevention and the crisis management perspective. A changing perspective in the interpretation of the causes, early identification and corrective measures used in the context of (near) failures may create difficulties when trying to compare past failures with current ones, particularly with the advent of recovery and resolution frameworks in finance.

EIOPA has developed its own conceptual approach, which is followed throughout this report. It should be stressed that there is not a conceptual approach which is universally agreed. The aim of the present chapter is to explain the approach followed by EIOPA, in order to achieve a common understanding and support the classification of the different cases of insurance failures and near misses.

This chapter focuses on the following two issues:

  • The definition of the concepts of “failure” and “near miss”, which are essential to understanding the database construction process and the scope of the cases to be included.
  • The need to have a common understanding of the framework for crisis prevention and management, as well as the recovery and resolution tools to be used.

In terms of crisis prevention and management, the fundamental approach followed by EIOPA can be understood as part of a continuum of supervisory activities. Illustration 1 below summarizes the whole process: During business as usual, and in the normal stages of supervision, an initial problem can be identified, and insurers may seek to implement measures to overcome the problem. Supervisors would, in turn, normally intensify supervision and follow-up more closely on the developments of the insurer. Should the initial problem become a real financial threat (e.g. being in breach of, or about to breach, solvency capital requirements) the insurer enters into a new stage, which is linked to an increased risk of failure, i.e. a near miss situation. In this context, the insurer should trigger certain recovery actions to restore its financial position, while supervisors can intervene more intrusively. In general, there should be a reasonable prospect of recovery if effective and credible measures are implemented. Nevertheless, if the situation of distress is extremely severe and the measures taken do not yield the expected results, the insurer enters into resolution.

Eventually, the insurer (or parts of it) is (are) wound-up and exits the market.

EIOPA - Resolution

Near miss

In the context of this report, a near miss is defined as a case where an insurer faces specific financial difficulties (for example, when the solvency requirements are breached or likely to be breached) and the supervisor feels it necessary to intervene or to place the insurer under some form of special measures.

The elements to identify a near miss are the following:

  • The insurer is still in operation under its original form;
  • Nevertheless it is subject to a severe financial distress to an extent that the supervisory authority deems it necessary to intervene; and
  • In the absence of this intervention, the insurer will not survive in its current form and may eventually go into resolution or be wound-up.

Underlying is the idea of success of the measures taken. As such, it should not involve public money or policyholders’ loss.

In other words, a near miss presupposes that the supervisory intervention, either directly (e.g. replacing the management) or indirectly (e.g. request for an increase in capital), contributed in a clear way to overcome the insurer’s financial distress and bring it back to a “business-as-usual” environment. Shareholders generally keep their rights and could potentially oppose any of the measures undertaken.

On a day-to-day basis, insurers and NSAs might have to take different actions that require a certain degree of coordination. A “near miss” in the sense described in this report should be distinguished from these type of situations. Near misses only refer to cases where severe problems were detected or reported and supervisory measures were necessary to ensure the viability of the insurer.

Near misses actually constitute an area of particular interest for this report. In effect, their correct reporting and analysis would allow valuable lessons to be learned from successfully managed distress situations – prospective failure of an insurer and supervisory actions that permitted recovery.

Insurance failure

A failure, for the purposes of the present database, exists from the moment when an insurer is no longer viable or likely to be no longer viable, and has no reasonable prospect of becoming so.

The processes of winding-up/liquidation, which are usually initiated after insolvency, either on a balance sheet basis (the insurer’s liabilities are greater than its assets) or cash-flow basis (the insurer is unable to pay its debts as they fall due), are also encompassed within the definition of failure for the purposes of the database. Failure is thus triggered by “non-viability”.

The failed insurer ceases to operate in its current form. Shareholders generally lose some or all of their rights and cannot oppose to the measures taken by the authority in charge of resolution, which has formally taken over the reins from the supervisory authority.

For classification purposes, any case is considered as a failure (regardless of the final result of the intervention) when:

  • Private external support (e.g. by means of an insurance guarantee system (IGS)) has been received.
  • Public funds by taxpayers were needed for policyholders’ protection or financial stability reasons.
  • Policyholders have suffered any type of loss, be it in financial terms or in a deterioration of their insurance coverage.

The following are examples of resolution tools that may be used by authorities in a case of failure:

  • Sale of all or part of the insurers’ business to a private purchaser. A particular case is the transfer of an insurers’ portfolio, moving all or part of its business to another insurer without the consent of each and every policyholder.
  • Discontinue the writing of new business and continue administering the existing contractual policy obligations for inforce business (run-off).
  • Set-up a bridge institution as a temporary public entity to which all or part of the business of the insurer is transferred in order to preserve its critical functions.
  • Separate toxic assets from good assets establishing an asset management vehicle (i.e. a “bad insurer” similar to the concept used in banking) wholly owned by one or more public authorities for managing and running-down those assets in an orderly manner.
  • Restructure, limit or write down liabilities (including insurance and reinsurance liabilities) and allocate losses following the hierarchy of claims.

This also includes the bail-in of liabilities when they are by converted into equity.

  • Closure and orderly liquidation of the whole or part of a failing insurer.
  • Withdrawal of authorisation.

Lastly, it should be mentioned that the flow of events shown in Illustration 1 does not necessarily take place in a sequential way. For example, there could be cases in which an insurer goes directly into resolution. Thus, what is relevant for the classification of a particular case is whether the insurer recovers (which would then be considered as a near miss or as a case resolution/return to market if some kind of resolution action/tool is used) or has to be fully resolved and/or liquidated.

EIOPA - Sharma Risks

Click here to access EIOPA’s detailed report

Global Governance Insights on Emerging Risks

Publié le par hanswillertbleuazurconsultingeu

A HEIGHTENED FOCUS ON RESPONSE AND RECOVERY

Over a third of directors of US public companies now discuss cybersecurity at every board meeting. Cyber risks are being driven onto the agenda by

  • high-profile data breaches,
  • distributed denial of services (DDoS) attacks,
  • and rising ransomware and cyber extortion attacks.

The concern about cyber risks is justified. The annual economic cost of cyber-crime is estimated at US$1.5 trillion and only about 15% of that loss is currently covered by insurance.

MMC Global Risk Center conducted research and interviews with directors from WCD to understand the scope and depth of cyber risk management discussions in the boardroom. The risk of cyberattack is a constantly evolving threat and the interviews highlighted the rising focus on resilience and recovery in boardroom cyber discussions. Approaches to cyber risks are maturing as organizations recognize them as an enterprise business risk, not just an information technology (IT) problem.

However, board focus varies significantly across industries, geographies, organization size and regulatory context. For example, business executives ranked cyberattacks among the top five risks of doing business in the Asia Pacific region but Asian organizations take 1.7 times longer than the global median to discover a breach and spend on average 47% less on information security than North American firms.

REGULATION ON THE RISE

Tightening regulatory requirements for cybersecurity and breach notification across the globe such as

  • the EU GDPR,
  • China’s new Cyber Security Law,
  • and Australia’s Privacy Amendment,

are also propelling cyber onto the board agenda. Most recently, in February 2018, the USA’s Securities and Exchange Commission (SEC) provided interpretive guidance to assist public companies in preparing disclosures about cybersecurity risks and incidents.

Regulations relating to transparency and notifications around cyber breaches drive greater discussion and awareness of cyber risks. Industries such as

  • financial services,
  • telecommunications
  • and utilities,

are subject to a large number of cyberattacks on a daily basis and have stringent regulatory requirements for cybersecurity.

Kris Manos, Director, KeyCorp, Columbia Forest Products, and Dexter Apache Holdings, observed, “The manufacturing sector is less advanced in addressing cyber threats; the NotPetya and WannaCry attacks flagged that sector’s vulnerability and has led to a greater focus in the boardroom.” For example, the virus forced a transportation company to shut down all of its communications with customers and also within the company. It took several weeks before business was back to normal, and the loss of business was estimated to have been as high as US$300 million. Overall, it is estimated that as a result of supply chain disruptions, consumer goods manufacturers, transport and logistics companies, pharmaceutical firms and utilities reportedly suffered, in aggregate, over US$1 billion in economic losses from the NotPetya attacks. Also, as Cristina Finocchi Mahne, Director, Inwit, Italiaonline, Banco Desio, Natuzzi and Trevi Group, noted, “The focus on cyber can vary across industries depending also on their perception of their own clients’ concerns regarding privacy and data breaches.”

LESSONS LEARNED: UPDATE RESPONSE PLANS AND EVALUATE THIRD-PARTY RISK

The high-profile cyberattacks in 2017, along with new and evolving ransomware onslaughts, were learning events for many organizations. Lessons included the need to establish relationships with organizations that can assist in the event of a cyberattack, such as l

  • aw enforcement,
  • regulatory agencies and recovery service providers
  • including forensic accountants and crisis management firms.

Many boards need to increase their focus on their organization’s cyber incident response plans. A recent global survey found that only 30% of companies have a cyber response plan and a survey by the National Association of Corporate Directors (NACD) suggests that only 60% of boards have reviewed their breach response plan over the past 12 months. Kris Manos noted, “[If an attack occurs,] it’s important to be able to quickly access a response plan. This also helps demonstrate that the organization was prepared to respond effectively.”

Experienced directors emphasized the need for effective response plans alongside robust cyber risk mitigation programs to ensure resilience, as well as operational and reputation recovery. As Jan Babiak, Director, Walgreens Boots Alliance, Euromoney Institutional Investor, and Bank of Montreal, stressed, “The importance of the ’respond and recover’ phase cannot be overstated, and this focus needs to rapidly improve.”

Directors need to review how the organization will communicate and report breaches. Response plans should include preliminary drafts of communications to all stakeholders including customers, suppliers, regulators, employees, the board, shareholders, and even the general public. The plan should also consider legal requirements around timelines to report breaches so the organization is not hit with financial penalties that can add to an already expensive and reputationally damaging situation. Finally, the response plan also needs to consider that normal methods of communication (websites, email, etc.) may be casualties of the breach. A cyber response plan housed only on the corporate network may be of little use in a ransomware attack.

Other lessons included the need to focus on cyber risks posed by third-party suppliers, vendors and other impacts throughout the supply chain. Shirley Daniel, Director, American Savings Bank, and Pacific Asian Management Institute, noted, “Such events highlight vulnerability beyond your organization’s control and are raising the focus on IT security throughout the supply chain.” Survey data suggests that about a third of organizations do not assess the cyber risk of vendors and suppliers. This is a critical area of focus as third-party service providers (e.g., software providers, cloud services providers, etc.) are increasingly embedded in value chains.

FRUSTRATIONS WITH OVERSIGHT

Most directors expressed frustrations and challenges with cyber risk oversight even though the topic is frequently on meeting agendas. Part of the challenge is that director-level cyber experts are thin on the ground; most boards have only one individual serving as the “tech” or “cyber” person. A Spencer Stuart survey found that 41% of respondents said their board had at least one director with cyber expertise, with an additional 7% who are in the process of recruiting one. Boards would benefit from the addition of experienced individuals who can identify the connections between cybersecurity and overall company strategy.

A crucial additional challenge is obtaining clarity on the organization’s overall cyber risk management framework. (See Exhibit 1: Boards Need More Information on Cyber Investments.) Olga Botero, Director, Evertec, Inc., and Founding Partner, C&S Customers and Strategy, observed, “There are still many questions unanswered for boards, including:

  • How good is our security program?
  • How do we compare to peers?

There is a big lack of benchmarking on practices.” Anastassia Lauterbach, Director, Dun & Bradstreet, and member of Evolution Partners Advisory Board, summarized it well, “Boards need a set of KPIs for cybersecurity highlighting their company’s

  • unique business model,
  • legacy IT,
  • supplier and partner relationships,
  • and geographical scope.”

CR Ex 1

Nearly a quarter of boards are dissatisfied with the quality of management-provided information related to cybersecurity because of insufficient transparency, inability to benchmark and difficulty of interpretation.

EFFECTIVE OVERSIGHT IS BUILT ON A COMPREHENSIVE CYBER RISK MANAGEMENT FRAMEWORK

Organizations are maturing from a “harden the shell” approach to a protocol based on understanding and protecting core assets and optimizing resources. This includes the application of risk disciplines to assess and manage risk, including quantification and analytics. (See Exhibit 2: Focus Areas of a Comprehensive Cyber Risk Management Framework.) Quantification shifts the conversation from a technical discussion about threat vectors and system vulnerabilities to one focused on maximizing the return on an organization’s cyber spending and lowering its total cost of risk.

CR Ex 2

Directors also emphasized the need to embed the process in an overall cyber risk management framework and culture. “The culture must emphasize openness and learning from mistakes. Culture and cyber risk oversight go hand in hand,” said Anastassia Lauterbach. Employees should be encouraged to flag and highlight potential cyber incidents, such as phishing attacks, as every employee plays a vital role in cyber risk management. Jan Babiak noted, “If every person in the organization doesn’t view themselves as a human firewall, you have a soft underbelly.” Mary Beth Vitale, Director, GEHA and CoBiz Financial, Inc., also noted, “Much of cyber risk mitigation is related to good housekeeping such as timely patching of servers and ongoing employee training and alertness.”

Boards also need to be alert. “Our board undertakes the same cybersecurity training as employees,” noted Wendy Webb, Director, ABM Industries. Other boards are putting cyber updates and visits to security centers on board “offsite” agendas.

THE ROLE OF CYBER INSURANCE

Although the perception of many directors is that cyber insurance provides for limited coverage, the insurance is increasingly viewed as an important component of a cyber risk management framework and can support response and recovery plans. Echoing this sentiment, Geeta Mathur, Director, Motherson Sumi Ltd, IIFL Holdings Ltd, and Tata Communication Transformation Services Ltd., commented, « There is a lack of information and discussion on risk transfer options at the board level. The perception is that it doesn’t cover much particularly relating to business interruption on account of cyber threats.” Cristina Finocchi Mahne also noted, “Currently, management teams may not have a positive awareness of cyber insurance, but we expect this to rapidly evolve over the short-term.”

Insurance does not release the board or management from the development and execution of a robust risk management plan but it can provide a financial safeguard against costs associated with a cyber event. Cyber insurance coverage should be considered in the context of an overall cyber risk management process and cyber risk appetite.

With a robust analysis, the organization can

  • quantify the price of cyber risk,
  • develop effective risk mitigation,
  • transfer and risk financing strategy,
  • and decide if – and how much – cyber insurance to purchase.

This allows the board to have a robust conversation on the relationship between risk, reward and the cost of mitigation and can also prompt an evaluation of potential consequences by using statistical modeling to assess different damage scenarios.

CYBER INSURANCE ADOPTION IS INCREASING

The role of insurance in enhancing cyber resilience is increasingly being recognized by policymakers around the world, and the Organisation of Economic Co-operation and Development (OECD) is recommending actions to stimulate cyber insurance adoption.

Globally, it is expected the level of future demand for cyber insurance will depend on the frequency of high-profile cyber incidents as well as the evolving legislative and regulatory environment for privacy protections in many countries. In India, for example, there was a 50% increase in companies buying cybersecurity coverage 2016 to 2017. Research suggests that only 40% of US boards have reviewed their organization’s cyber insurance coverage in the past 12 months.

LIMITING FINANCIAL LOSSES

In the event of a debilitating attack, cyber insurance and associated services can limit an organization’s financial damage from direct and indirect costs and help accelerate its recovery. (See Exhibit 3: Direct and Indirect Costs Associated with a Cyber Attack.) For example, as a result of the NotPetya attack, one global company reported a decline in operating margins and income, with losses in excess of US$500 million in the last fiscal year. The company noted the costs were driven by

  • investments in enhanced systems in order to prevent future attacks;
  • cost of incentives offered to customers to restore confidence and maintain business relationships;
  • additional costs due to claims for service failures; costs associated with data breach or data loss due to third-parties;
  • and “other consequences of which we are not currently aware but may subsequently discover.”

Indeed, the very process of assessing and purchasing cyber insurance can bolster cyber resilience by creating important incentives that drive behavioral change, including:

  • Raising awareness inside the organization on the importance of information security.
  • Fostering a broader dialogue among the cyber risk stakeholders within an organization.
  • Generating an organization-wide approach to ongoing cyber risk management by all aspects of the organization.
  • Assessing the strength of cyber defenses, particularly amid a rapidly changing cyber environment.

CR Ex 3

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Cybersecurity Risk Management Oversight – A Tool for Board Members

Publié le par hanswillertbleuazurconsultingeu

Companies are facing not only increasing cyber threats but also new laws and regulations for managing and reporting on data security and cybersecurity risks.

Boards of directors face an enormous challenge: to oversee how their companies manage cybersecurity risk. As boards tackle this oversight challenge, they have a valuable resource in Certified Public Accountants (CPAs) and in the public company auditing profession.

CPAs bring to bear core values—including independence, objectivity, and skepticism—as well as deep expertise in providing independent assurance services in both the financial statement audit and a variety of other subject matters. CPA firms have played a role in assisting companies with information security for decades. In fact, four of the leading 13 information security and cybersecurity consultants are public accounting firms.

This tool provides questions board members charged with cybersecurity risk oversight can use as they engage in discussions about cybersecurity risks and disclosures with management and CPA firms.

The questions are grouped under four key areas:

  1. Understanding how the financial statement auditor considers cybersecurity risk
  2. Understanding the role of management and responsibilities of the financial statement auditor related to cybersecurity disclosures
  3. Understanding management’s approach to cybersecurity risk management
  4. Understanding how CPA firms can assist boards of directors in their oversight of cybersecurity risk management

This publication is not meant to provide an all-inclusive list of questions or to be seen as a checklist; rather, it provides examples of the types of questions board members may ask of management and the financial statement auditor. The dialogue that these questions spark can help clarify the financial statement auditor’s responsibility for cybersecurity risk considerations in the context of the financial statement audit and, if applicable, the audit of internal control over financial reporting (ICFR). This dialogue can be a way to help board members develop their understanding of how the company is managing its cybersecurity risks.

Additionally, this tool may help board members with cybersecurity risk oversight learn more about other incremental offerings from CPA firms. One example is the cybersecurity risk management reporting framework developed by the American Institute of CPAs (AICPA). The framework enables CPAs to examine and report on management-prepared cybersecurity information, thereby boosting the confidence that stakeholders place on a company’s initiatives.

With this voluntary, market-driven framework, companies can also communicate pertinent information regarding their cybersecurity risk management efforts and educate stakeholders about the systems, processes, and controls that are in place to detect, prevent, and respond to breaches.

AICPA

Click here to access CAQ’s detailed White Paper and Questionnaires