FEAS Yearbook FEAS Yearbook 2003 | Page 15

HEWLETT-PACKARD • Operational risk assessment workshops and mitigation strategies for IT risks have been held with all stakeholders concerned Security Awareness and training has been done for Senior Operational Management • Organisational risk analysis has taken place • Policy development has been done and is in place • For major risks, there are mitigation plans, key risk indicators and auditable proof that the plans have worked • Show that the Business Continuity plan is up to date and worked at the last rehearsal • Security architecture and IT architecture development work has been done and signed off by the Board • Security audit of existing and proposed solutions is regularly executed • Demonstrate use of ITSM (IT Service Management) for data centre processes For each principle of operational risk management, there are actions that management can use to prove best effort and compliance. The most basic point to demonstrate is that operational risk assessment is done and done regularly and that for each important risk (defined as those risks for which the bank has no appetite..), a mitigation plan is in place, key risk indicators are known, accepted and tracked and demonstrable proof is kept of the success of the mitigation plans. In this process, it is clear that for the overwhelming majority of operational risk, there is no quantitative data either for the impact or the probability of occurrence. The only method that can be used is a qualitative judgment method. The best way to do this is to involve many stakeholders in the judgement process – this not only provides many points of view but also can solve the problem of risk appetite. As an example of this problem, if a person is asked if they accept a risk, they usually refuse – it is only when they are persuaded that the damage is minor that they might accept. For this reason, involving business and senior management in the risk qualification process is critical. CONCLUSION Whilst the accords propose that full operational risk management be implemented, there appears to be a greater focus on the loss database area than on the organisational and root cause issues, to the point that presentation of a good loss database would seem to be enough to persuade the regulator. If there is to be any comparability between compliance in different organisations under different regulators, it is important to separate operational risk mitigation and control from compliance to Basel 2 for capital adequacy reporting. The actions required for each are different (though they overlap) and the people required for each are different. Having two separate teams to address each issue is probably a good idea. Complying with the requirements of Basel 2 for the purposes of convincing the regulatory authorities that capital adequacy provisions are met places more focus on: • Gathering data and refining its quality • Managing the data volume (less is more…) • Assessing the indicators • Calculating capital adequacy as a percentage of the sum of the risks for a period • Gaining regulator agreement on the figure • Storing data in a secure and available way • Refining operations to ensure that data is captured in the future • Reporting internally and externally whereas controlling operational risk should focus mainly on: • Identifying risks • Prioritizing risks • Determining impacts quantitatively and qualitatively • Determining probabilities • Putting mitigation plans in place • Putting controls in place • Tracking and auditing controls • Performing regular risk re-assessments and change control • Reporting directly or indirectly via certification It would seem to make sense that the accords be very prescriptive on the control side rather than advising subjective compliance to principles. The Basel Accords should be used as an opportunity for a fundamental reassessment of the whole operational infrastructure and control framework otherwise the statistics for operational losses will continue to worsen. HP’s suggestion to banks is to avoid an either/or decision about the way forward. Now that the momentum is there to view operational risk as an important parameter of business success, banks should not stop with a formalized documentation of their current risk situation, but use this opportunity and also mitigate the identified risks in a proactive way. HP’s portfolio of services and solutions is created to accompany banks on both routes - Basel 2 compliance and mastering operational risk. by Stuart Hotchkiss, Lead Security Consultant FSI, HPS Consulting & Integration contribution by Alexander de Lange, HP Director International Sales-Capital Markets-CEEMEA. FEDERATION OF EURO-ASIAN STOCK EXCHANGES YEARBOOK 2003/2004 PAGE 13