How do we move to more value-oriented risk management, rather
than compliance-oriented risk management?
This topic seems to be on many lips
these days. At ValueBridge we recommend several actions:
Integrating risk management with other business improvement activities (BPM,
QC, BA, PM and more); making balanced improvements in risk management capabilities to avoid stumbling over the weak stops; engaging the
organization to get more people invested in success and more resources;
understanding how to prepare for and respond to changing conditions; and using
measurements and incentives to bring alignment to the various functional areas of
the bank around the business processes involved. Sounds overwhelming. Yet, this
is where leveraging cross-industry best practices and a kit bag of solid
techniques can makes it faster and easier.
What do I have to know to blend business process and IT-related
operational risks together?
If you are already talking about
"business processes" and have a view of them, you are well on your way.
Manual processes and the "stack" of IT stuff on which they run are
increasingly important, the more that banks become automated and integrated
in the rush to cut costs. The pace of acquisitions just adds to
this. The work you really need to do is very simple in concept:
1) understand what IT stuff is running your business process (and where it
located), 2) understand the threats to the business process and that stack
of stuff (threats can be malicious, natural, accidental or business, 3) the
implications if those threats occur and 4) what you need to do on an
end-to-end process basis to manage those threats (and the impact to
liquidity as the regulatory guidance states). Simple in concept, yet
you face a number of challenges, including: 1) crossing the organization
silos and 2) actually knowing how processes run in your enterprise.
The good news is that there are again cross-industry best practices and a
kit bag of solid techniques that can makes your task faster and easier.
Is there more to scenario analysis than "long tail" validation?
In banking operational risk management, scenario analysis has largely
been used to validate "long tail" (that is low probability) events. Yes, it
can be used more broadly. In fact, check with your strategic planning or
business continuity departments, which might already be using scenario
analysis in broader ways to more accurately reflect real threats to real
banking operations. If you have ever worked in foreign exchange, they
also use scenarios in broader ways (especially those who work directly with
clients providing FX services). Banks have the opportunity to use scenario
analysis in the same way that other industries have. Whether
manufacturing plants, beer breweries, oil & gas, delivery trucks or
telecommunications; they all have lessons to teach. So the opportunity is to
use scenario analysis to move from compliance-driven risk management to
performance-driven risk management. In doing so, it is important to
start by measuring maturity in several dimensions and evenly work to improve
those areas.
Our
business continuity program is improving, we have good times for
recovery on our services, building evacuation and transfer to
alternative work locations. Is there more we need to do?
For various historical reasons, including the way that compliance tests
were designed, recovery time objectives (RTOs) were emphasized at the level
of an individual resource (server, network, moving people). However business
operations are simply not conducted at that level of individual resources or
assets. To provide service to customers and others users, all aspects of a
business process must be running. The relevant tests are the ability to
process merchant transactions in total, the ability to stock cash in ATM
machines, the ability to put inventory on shelves, the ability to ship
parts, the ability to communicate with customers. The opportunity for
improvement is to conduct end to end business processes based continuity
planning. Two other important considerations are:
1. To evaluate range
of threats to the range of operations. Too often "continuity" is
thought of only in the limited sense of natural disasters or maybe
terrorism. Yet, programming errors, cable cuts and human accidents
have also resulted in great loss to organizations.
2. Ensuring
that systems management tools are also considered in recovery
efforts and recovery cycle time. This is an often looked but
serious consideration. In the 2003 U.S. Northeast Electrical
Blackout, failures in the systems management recovery process were a
contributing cause.
Especially for financial institutions, learn
more about fast-start workshops.