Operational Risk - Bank Management - Study Notes, Study notes of Banking and Finance

Topics that are to be discussed are credit creation process in banks, performance analysis of banks, risk management of banks - interest rate risk, credit risk and operational risk; treasury operations and bond portfolio management in banks; pricing of products offered by banks - deposits, loans and other services. Operational, Risk, Policy, Measurement, Management, Fraud Detection, Factors, Approaches

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2011/2012

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OperationalRisk
Operationalriskcanbedefinedasariskarisingfromdirectorindirectlosstothebank.Thecausesof
losscanbeassociatedwithinadequateorfailedinternalprocess,peopleandsystems.Besides
internallyoccurringevents,thepeople,processandsystemsfailurecouldalsooccurduetoexternal
events.Operationalrisknecessarilyexcludesbusinessriskandstrategicrisk.
Thecomponentsofoperationalriskincludestransactionprocessingrisk,informationsecurityrisk,
legalrisk,complianceriskandriskoccurringduetothefunctioningofhumanresourcesofthebank.
Peopleriskarisesfromlackoftrainedkeypersonnel,tamperingofrecords,unauthorizedaccessto
dealingroomsandnexusbetweenfrontandbackendoffices.
Processriskarisesonaccountoffaultyreportingofimportantmarketdevelopmentstothebank
managementmayalsooccurduetoerrorsinentryofdataforsubsequentbankcomputations.Non‐
monitoringofexposurepositionsalsoresultinprocessrisksforthebank.Besides,banksmayalso
supplyneededfundsincurrenciesthatmayleadtoalossforthebankduetothecurrencyrate
fluctuations.Whenthebankcreatesnewproductswithoutproperconsiderationofitslongterm
implicationsthebankmayalsoencounterprocessrisk.
Systemsriskinvolveslossesduetosystemsfailure,lackofsecurityfortheinformationrequirements
ofthebank,inadequateinvestmentsmadeintermsoftechnologyrequirements,snagsin
implementationofsystems,inadequatesystemscapacityorfailureinsystemsdevelopments.
Riskonaccountofexternalfactorsarisesduetolegalandregulatorychanges,outsourcingrisk,
supplierrisk,politicalriskandGovernmentpolicyrisk.Banksareexpectedtofunctioninaspecific
infrastructuresetupcreatedintheeconomysuchasfundtransfermechanisms.Thefailureofsuch
infrastructureleadstorisktothebankthroughexternalfactors.
Operationallossesarelargelossesarisingfromoperationswhichmaybeintheformofpayments
madetothirdpartiesonlawsuits,taxpenalties,compliancewithregulationsanddamagetoassets.
Compensationpaidtocustomers,theft,fraudsincludingroguetradingandlatesettlementor
settlementtothewrongcounterpartyarethemajortypesofoperationallossthatareincurredby
thebanks.
OperationalRiskPolicy
Banksshouldlaydownclearoperationalriskmanagementpolicies.Itincludesplanning,
identification,classificationandreportingprocedures.Policyofthebankslaysdownthebusiness
unitsthatthebankislikelytoengagein.Thebusinesslinesthataretobepromotedwithintheunits
andtheactivitygroupsthatareplannedtoexecutethebusinessobjectivesoftheunitsarespecified
inthepolicystatements.
Illustrationsofbusinessunitsbydifferenttypesofbanksaregivenbelow.
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Operational Risk

Operational risk can be defined as a risk arising from direct or indirect loss to the bank. The causes of loss can be associated with inadequate or failed internal process, people and systems. Besides internally occurring events, the people, process and systems failure could also occur due to external events. Operational risk necessarily excludes business risk and strategic risk.

The components of operational risk includes transaction processing risk, information security risk, legal risk, compliance risk and risk occurring due to the functioning of human resources of the bank.

People risk arises from lack of trained key personnel, tampering of records, unauthorized access to dealing rooms and nexus between front and back end offices.

Process risk arises on account of faulty reporting of important market developments to the bank management may also occur due to errors in entry of data for subsequent bank computations. Non‐ monitoring of exposure positions also result in process risks for the bank. Besides, banks may also supply needed funds in currencies that may lead to a loss for the bank due to the currency rate fluctuations. When the bank creates new products without proper consideration of its long term implications the bank may also encounter process risk.

Systems risk involves losses due to systems failure, lack of security for the information requirements of the bank, inadequate investments made in terms of technology requirements, snags in implementation of systems, inadequate systems capacity or failure in systems developments.

Risk on account of external factors arises due to legal and regulatory changes, outsourcing risk, supplier risk, political risk and Government policy risk. Banks are expected to function in a specific infrastructure setup created in the economy such as fund transfer mechanisms. The failure of such infrastructure leads to risk to the bank through external factors.

Operational losses are large losses arising from operations which may be in the form of payments made to third parties on law suits, tax penalties, compliance with regulations and damage to assets. Compensation paid to customers, theft, frauds including rogue trading and late settlement or settlement to the wrong counterparty are the major types of operational loss that are incurred by the banks.

Operational Risk Policy

Banks should lay down clear operational risk management policies. It includes planning, identification, classification and reporting procedures. Policy of the banks lays down the business units that the bank is likely to engage in. The business lines that are to be promoted within the units and the activity groups that are planned to execute the business objectives of the units are specified in the policy statements.

Illustrations of business units by different types of banks are given below.

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Management of Operational Risk

Basel committee has framed guidelines for managing credit risk, market risk and operational risk of banks. The committee has updated the guidelines pertaining to these risks frequently. The regulatory compliance aims at curbing money laundering practices, undesirable banking practices, regulation of product quality and cross boarder business of banks.

Operational risk management aims at improving return on capital for the banks, managing volatility of returns and value optimization.

While regulatory authorities come out with prudential norms and good governance practices to curb operational risk, the market response is in terms of developing innovative products such as equity futures, foreign currency futures, currency swaps and options. As part of controlling operational risk, bank management introduces a series of initiatives to control internal fraud. These include proper authorization of activities, reporting of transactions, measurement of operational risk positions, asset valuation and regulatory compliance. Customer level initiatives include generation of reliable credit reports, monitoring worthless deposits, measures to check extortion, embezzlement and asset misappropriation.

As far as cross boarder business is concerned bank initiatives includes verification of accounts transfer, penalties for non compliance and willful evasion, identification of irregular movement of funds. Information security, detection of forgery and prevention of hacking are other fraud management measures that are to be taken up by banks.

To prevent employees committing fraud, banks should initiate steps to provide adequate compensation and other employee benefits and formulate best promotion and termination policies, promote good employee relations, health and safety rules and seek legal support for employee related problem management.

With regard to customers, banks should enforce disclosure requirements and ensure privacy and confidentially of information and avid aggressive selling. The banks have to scrutinize their exposure limits and come out with best banking products. To support its best practices, banks need to have an error free efficient systems management.

Proper implementation of operational risk management practices should encompass customer permissions, proper documentation, faultless procedures and introduction of disclaimer clauses wherever necessary.

Questions

  1. What is operational risk?
  2. What are the components of operational risk?
  3. What are the factors to be considered while framing an operational risk policy for a bank?
  4. What are the approaches for operational risk measurement?
  5. What internal control systems should be initiated for operational risk management?
  6. Explain how operational losses are computed.
  7. Explain the Basel norms for operational risk measurement.
  8. What are the measures to be taken by the bank to reduce operational risk?