FEAS Yearbook FEAS Yearbook 2003 | Page 14

HEWLETT-PACKARD Given this parlous state of operational risk management and losses from it and the focus we need to place on the IT infrastructure, it seems that this problem cannot be solved by a single action. Looking at the content of loss databases (historical or current) presents some other problems. There may be too much data and there may be many events that relate to a single root cause. Too much data is no better than no data; it is just a different problem. With too much data, prioritising and gaining management and operational attention can be hard if not impossible. With no data, there is a false sense of well-being. Data should only be collected when triggers indicate that a risk is out of bounds. To do this, the whole operational risk management system needs to be designed correctly (which, if it was, would mean this would not happen…) Event correlation with large amounts of data is a headache but it is often true that many events come from a single root cause – the trick is finding it. What is the answer? It has been estimated that the 20 largest banks in the U.S. had operational risk losses in 2001 of US$ 2.5 billion and that barely twenty percent of banks could be considered as having operations under tight control. The losses from security breaches are similarly high in spite of huge spending on mitigation solutions – the average amount admitted by companies voluntarily responding to the Computer Security Institute Review 2003 is nearly one million dollars per year. Given this parlous state of operational risk management and losses from it and the focus we need to place on the IT infrastructure, it seems that this problem cannot be solved by a single action. Indeed it will never be solved completely to the point of having zero operational loss. All we can do is reduce the complexity of the equation by reducing the number of variables requiring management attention. We need to recap on the reason for Basel 2 – capital adequacy leading to trust. Part of the trust issue is due diligence and part is external trust. There will be banks that have higher capital adequacy than required but that can’t CONTACT INFORMATION Contact Name Mr. Alexander de Lange Mr. Stuart Hotchkiss E-mail [email protected] [email protected] Website www.hp.com FEDERATION OF EURO-ASIAN STOCK EXCHANGES YEARBOOK 2003/2004 PAGE 12 be trusted. The regulator and business partners are looking for the objective and subjective elements that inspire trust. Having a good loss database might not convince the regulator or business partners that operations are under control if, for example, the business continuity plan can’t be demonstrated. Inspiring trust is the key issue. Reducing operational complexity would be nice but is not an easy or short-term objective - inspiring trust by being able to demonstrate control is. There are control frameworks such as ISO17799 (best practice for security), BS7799 Part 2 (security management, including operations) and COBIT (Control Objectives for Information and related Technology) that can provide the objective, externally verifiable and comparable means of demonstrating that some of the elements of operations are under control. Complying with these not only reduces the number of non-controlled variables but it also inspires a culture in employees and management that can itself provide benefits. If we look at directors’ responsibilities in more detail, it is a good starting point to use the basic principles of operational control and to ask what would convince the regulator that compliance exists. BIS have published a number of reports demonstrating the principles and best practices of operational risk management – if we look specifically at one applied to e-banking: Principle 1: The board should establish effective management oversight over the risks associated with banking activities including the specific accountability, policies and controls to manage these risks. How can we demonstrate to a regulator that this requirement is met? It can’t be met objectively since the requirement is made subjective by the word ‘effective’. If it were shown to the regulator that best efforts had been made to comply with an industry standard control framework, this would help. If not, then specific things could be shown, for example, show that: