Part 4 Flashcards
Risk mitigation and it’s importance
= Implementing measures to reduce the liklihood and impact of identified risks.
Importance
* Protects organisations from potential losses
* Ensures business continuity
* Enhances operational resillience and regultory compliance
* Builds stakeholder confidence
Risk mitigation stratergies - ARSA
- Avoidance = eliminate activities or conditions that expose the firm to risk (i.e. avoid investing in high risk products)
- Reduction = implement controlsto reduce the liklihood or impact of risks (enhance cyber security measures)
- Sharing = transfering or sharing risk with other parties (ie insurance)
- Acceptance = Acknowledge risks and accept them but ensure additional controls are in place
Types of controls - PDCD
- Preventative - reduce liklihood of an event happening (segregation of duties, varying access, etc)
- Detective = detect events during or after they occur (exception reports, file reconciliations)
- Corrective - mitigate impacts after an event (redundancy plans/backups)
- Deterrent - act as a deterance to prevent errors from arrising
Control testing - 4 methods
- Self certification/inquiry - interviews with the control owner to understand the process in place. Limited to low risk/secondary controls types due to a lack of evidence
- Examination - review of supporting documentation providing assurance and is suitable for automated controls
- observation - real time oversight of control execution, suitbale for key controls to assess design and effectiveness
- Reperformance - most rigorous test, replicating control processes on sample transactions, provides the highest assurance and is reccomended for high risk environemnts
View week 4, page 10 for table overview
Indicators of poor controls
- Optimistic controls - over estimate the strength of the control and often become tick box exercises
- Duplicative controls - commonly the ‘4 eye check’ where someone else checks the same info. Dilutes responsibility. Works best when using different depertments (maker/checker)
- more of the same: adding more controls of the same design after a previous control failures
4 Types of human error leading to control breaks and solutions
- Slips - not paying attention, distracted, responsibilities not clear.
- Mistakes - incorrect actions caused by flawed/conflicting procedures and knowledge based errors driven by lack of training.
- violations - deliberate disregard for rules, mitigated bu supervision/firm culture
- Active vs latent errors - active=direct operator error like pressing the wrong button, entering too many zeros etc
latent = flawed processes/systems manifesting issues later down the line
Solutions include
* Checklists
* communication protocols
* standardisation
* Improved work environments
Risk transfers
- Moving teh risk consequence or cause over to another party
- Examples are insurance to cover losses from operational incidents
- Outsourcing - delegating non-core activities out to specialists
Considerations:
* Cost of risk transfer vs risk reduction
* reputational risk cannot be outsourced
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implementing risk mitigation measures
- prioritisation - prioritise mitigation measures based on risk assessments
- resource allocation - allocate sufficient funds/resources for effective implementation.
- training/awareness - provide training on risk mitigation plans
- documentation - document the mitigation measures and impelemtation process
Developing risk mitigation plans - 5 steps
- clearly descirbe the risk and potential impact
- outline the specific mitigation measures to reduce risk
- responsibilities to be assigned for implementing mitigation measures
- resources - identify the resources required to do the above
- timeline - establish a timeline for implementing the measures
monitoring and reviewing risk mtigiation measures
- Continuous montioring - using KRIs and other metrics to monitor risks
- Regular reviews - reveiws to assess controls effectivenenss
- Feedback loops - establish feedback mechanisms to capture lessons learned/improve plans
- Adjustment updates - make necessary adjustments to mitigation measures based on monitoring results and changing risk landscapes
Root cause analysis - uses what to identify problems,
= systematic process used to identify the underlying causes of problems or incidents.
* helps identify why an issue occured and prevents it from happening again
* Importance - essential for problem solving and continuous improvement in op risk mgmt.
Root cause analysis - best practices, BCBS revue standard and the roles of each, what type of Template
- Root cause analysis - essential for material op risk events/near misses. BCBS reccomends having RCA thresholds that are reviewed by 1st+2nd line of defence
- 1st LOD - leads RCA and creates action points based on control deficiencies
- 2nd LOD - monitors and tracks action items identified by 1st LOD and escalates issues to senior mgmt where needed.
- Standardised templates help conduct RCA consistently. Sharing details of risk events across LOBs also helps understanding.
benefits of root cause analysis
- true cause identification - identifies the true cause of the problems and not just symptoms/impacts
- recurrance reduction - reduces the liklihood of similar issues recurring if mitigation methods are implimented correctly post RCA.
- Long term solutions - helps develop sustainable solutons rather than temporary fixes
- Operational efficiency - enhances overall operational efficiency and effectiveness by addressing root causes of issues.
Bow tie tool - common features
- Imbalanced preventative/detective controls, leading to the firm haviing to fiure fight and remidiate every time something goes wrong.
- Defective internal communication flows leading to duplicated efforts or one LOB doing something harmful to anotehr LOB by mistake.
- Excessively low red KRI thresholds - makes identifying true red events hard
- Poor third party management processes if risks are outsourced
Steps in a route cause analysis
- Define the problem - clearly describe the issue and teh impact
- Collect data relevant to the problem
- identify possible causes of the issues
- Analyse the causes to find the route cause
- develop solutions and action plans to address the route cause
- implement and monitor the solutions and their efffectiveness
RCA Tools and Techniques
- 5 why’s- ask why multiple times to drill down to route causes
- fishbone diagram (ishikawa) - visual diagram to catagorise potential causes
- Pareto analysis - focuses on identifying the most significant causes using teh 80/20 rule
- Failure mode and effects analysis (FMEA) - systematic method for evaluating processes to identify where and how they can fail.
Action plans - design and governance. Purpose, who helps driving action plans
- Purpose = designed to reduce risk levels or improve processes/controls, typically following incidents or near misses that exceed the risk appetite.
- Not all incidents need an action plan - they are initiated when risk events/assessments reveal impacts above current appetite.
- However, discounnects between risk appetite and action plans can lead to wasted resources
- Clear ownership for execution, deadlines for implementation and consistency with the risk appetite are key elements in a successful action plan.
- 2nd LOD help design action plans to prevent the business don’t cut corners to save money
Developing action plans - POARRTE
- prblem statement - define the issue that needs addressing
- Objectives - state the desired outcomes off the action plan
- Actions - list actions required to address the route cause
- Responsibilities - assign roles/responsibilities for each action
- Resources - identify resources needed - money, people, etc
- Timeline - establish a timeline for implementing the actions
- Evaluation - define metrics and methods for evaluating teh effectiveness of the action plan
monitoring and reviewing action plans
- Continuous montioring - using KPIs and other metrics to monitor risks
- Regular reviews - reveiws to assess action plan’s effectivenenss
- Feedback loops - establish feedback mechanisms to capture lessons learned/improve plans
- Adjustment updates - make necessary adjustments to action plans based on monitoring results and changing risk landscapes
Future of RCA and action plans
- emerging trends - incorporate advances analytics and machine learning to enhance RCA
- Continuous improvement - ongoing refinement of RCA process using the latest tech and insights
- adaptation to change - flexibility to adapt RCA processes to changing risk appetites
- systematic approach - adoption of tools like bow tie analysis for more comprehensive root cause identification and action plans
Meaning of conduct and culture
- Conduct = behaviour of individuals within the organisation and how they adhere to policies rules and ethical standards.
- Culture = encompasses the shared values, beliefs and norms that influence how employees think, behave and interact with a firm
Importance = both conduct and culture are critical for establishing strong risk mgmt frameworks
Importance of conduct and culture
- Promotes ethics/integrity in the firm’s culture
- Fosters risk aware culture
- Stakeholder trust - builds trust among stakeholders including customers, employees and regulators
- sustainable success - long term success for the firm and risk resillience.
Factors to build a strong risk culture
- Commitment from management to risk mgmt and ethics
- Ckear values and expectations - define and communicate the organisation’s values and expected conduct
- Training and awareness - provide regular training on risk mgmt, ethics, etc
- open and transparent communication around risk and ethics
- accountability - establish accountability for risk mgmt at all levels.
‘Willingness and ability’ process for effecting changes
- Both willingness and ability are required to effect change.
- Training and guidance to close gaps in knowledge
- Clarifiying basics - clearly explained foundational concepts such as op risk events to ensure a base level of knowledge
Levels of incetives requried to achieve change
- Personal motivation dirven by the individual
- Social motivation driven by peers/peer pressure
- Structural motivation - encourgaed by formal rewards/incetive schemes
- Effective change - combining all 3 motivation levels with training is teh key to driving change
Propinquity and consistent message – influencing the environment
- Propinquity - fosters familiarity and understanding between teams. Achieved by putting teams with similar processes near each other to share ideas
- Occuational propinquity - psychological impact of working closely togther leads to acceptance over time and better relationshps
- Consistency - physcial environment should allign with company’s cultural messages.
using rules to influence a positive environment
- Incentive structures - ensure tehre is no conflict between remuneration and risk culture
- Positive reinforcement - recognise and reward good conduct, incident reporting and risk mgmt = boosts culture
- Risk based performance measures
- negative reinforcement - telling people off who break rules/fuck up
Assessing progress of influencing the environement.
- define success
- Set target behaviours and measurable criteria
- Track the behviours regularly
- Patience - not a quick process
Conduct risk - how is it assessed
= the risk of inappropriate, unethical or unlawful behaviour by employees.
Assessed by:
* Surveys/questionaires - get feeback on conduct issues
* Incident reporting systems - systems to track and report conduct issues
* Audits and reviews of policies and practices
* behavioral analysis - use data analytics to identify behaviour patterns
promoting ehtical conduct - stratergies
- code of conduct
- Leaders lead by example and make more ethical decisions
- Rewards and recognition for employees demonstrating ethical behaviour
- Protect whistleblowers
- regular training
Role of leadership in shaping culture
- Clear visions and values of the orgamisation
- Set and communicate behviour expectations
- Engaging and inclusive environment
- leadership acts accordingly with the code of conduct
- Feedback welcomed in order to improve
- Tools for measuring culture and conduct
- Culture surveys
- focus groups - get in depth insights
- performance metrics
- exit interviews - get feedback from people leaving the firm on culture
- 360 feedback for leadership and conduct
Benefits of positive culture and conduct
- better reputation
- better employee engagement
- Conduct risk mitigation
- Regulatory compliace
- driver better firm performance as a whole
done