The Changing Face of Enterprise Risk Management

CAACM 5th Annual Meeting & Conference
in Collaboration with ICATT
The Changing Face of Enterprise Risk
Management
July 13-15, 2011
Hyatt Regency - Trinidad and Tobago
1.347.891.9252
[email protected]
Rawle Mitchell
July 2011
Overview
• Risk has always been managed, somehow, or the other.
• As a concept RM evolved from the insurance industry where risk
financing was the main RM activity.
• Financial services crisis in 2008 demonstrated the extent to which
uncontrolled risk taking has damaged economies.
• RM for years was done by buying insurance.
• More recently companies managed risk through the capital
markets with “derivative” instruments.
• Risks that defy easy measurements like reputation, legal, human
resources have led to the emergence of ERM.
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Rawle Mitchell
July 2011
Risk Definition Through The Years
Definition
"Combination of the probability of occurrence of harm
and the severity of that harm."
"Combination of the probability of an event and its
consequence ."
"Chance of something happening that will have an
impact on objectives ."
"Events with a negative impact represents risks , which
can prevent value creation or erode existing value.
Events with positive impact may offset negative impacts
or represent opportunities ."
"The concept of risk refers in general to the magnitude
and likelihood of unanticipated changes that have an
impact on a firm's cash flows, value or profitability…Risk
has a negative connotation , but uncertainity can be a
source of opportunities as well as costs."
"Effect of uncertainty on objectives ."
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Rawle Mitchell
Source
ISO/IEC Guide 51:1999
ISO/IEC Guide 73:2002
AS/NZS 4360:2004
COSO (2004) ERM Integrated Framework
Lars Oxelheim & Clas
Wihlborg (2008) Corporate
Decision-Making with
Macroeconomic Uncertainity
ISO 31000:2009
July 2011
Risk Management Standards
Some of the popular standards:
• Australia/New Zealand (AS/NZS) Standard 4360 2004.
• COSO 2004 ERM - Integrated Framework
 Defines and prescribes a process for implementing ERM.
• The ISO 31000 (2009) -1st global risk management
standard.
 ISO 31000 definition has shifted the emphasis from the
“event” (something happening) to the “effect” – really the
effect on OBJECTIVES!
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Rawle Mitchell
July 2011
What is ISO?
• International Organization for Standardization (ISO) is the
world's largest developer and publisher of International
Standards.
• ISO is a specialized international organization founded in
Geneva in 1947 and concerned with standardization in all
technical and non-technical fields except electrical and
electronic engineering.
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Rawle Mitchell
July 2011
Why an ISO Standard in RM?
• Organizations around the world [be they public,
private, for profit, not-for-profit, multinational, etc.]
were facing increasing and greater risks and risk
management was not being consistently defined and
applied across sectors and countries.
• The challenges of inconsistent practices and
definitions thus give rise to the need for a universal
standard.
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Rawle Mitchell
July 2011
Why did ERM evolve?
•
Risk managers today need to manage known risks AND they must
also be prepared to cope with unknown risks that may manifest
themselves at any time.
•
•
Risk managers can only meet these demands if they operate at a
strategic level.
Calls for strengthening risk oversight have been occurring on an
increasing basis over the last several years.
•
•
NYSE (2004) adopted governance rules that require audit
committees of listed firms to oversee management’s risk oversight
processes.
More recently rating agencies, such as S & P, have begun to
explicitly evaluate an entity’s ERM processes as an input into their
credit ratings analysis.
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Rawle Mitchell
July 2011
Barriers to ERM Oversight
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Rawle Mitchell
July 2011
Marsh & RIMS 3 Levels of RM
1. Strategic RM incorporates all of the characteristics of traditional and
progressive approaches, but adds in measures with more of a “C-suite
view” of risk.
2. Companies that practice strategic RM tend to view risk as something to
optimize, not just to mitigate or avoid.
3. There is a concerted effort to index risk against competitors and against
the organization itself.
4. There is a stronger effort to weave risk issues into the overall conversation
about the firm’s business decisions.
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Rawle Mitchell
July 2011
Antecedents of ERM Implementation
• The idea that ERM is a key component of effective
governance has gained widespread acceptance.
• Literature review suggests five broad groups of factors
that determine extent of ERM implementation:
• Regulatory influences
• Internal influences
• Ownership
• Auditor influence
• Firm and industry-related characteristics
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Rawle Mitchell
July 2011
Why the Continuing RM evolution?
In light of so many financial failures, Robert P. Hartwig lashed
out at then current ERM frameworks. Hartwig:
 Financial crisis was the result of a failure of RM [in the banking and
securities markets] on a colossal scale.
 We may literally have to tear up the manual of ERM and start over.
 How did so many major financial players miss or overlook such huge,
systemic exposures?
But there is no “manual of enterprise risk management” to tear up.
Risk management is a general term referring to the overall process
of addressing risk, not any one particular method for mitigating risk.
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Rawle Mitchell
July 2011
Why the Continuing RM evolution?
But, RIMS contends that the financial crisis resulted from:
1. System-wide failure to embrace appropriate ERM behaviors - or
attributes - within these distressed organizations.
2. Failure to develop and reward internal RM competencies.
3. Failure to use ERM to inform management’s decision making for
both risk-taking and risk-avoiding decisions.
4. Over-reliance on the use of financial models, with the mistaken
assumption that the “risk quantifications” (used as predictions) based
solely on financial modeling were both reliable and sufficient tools to
justify decisions to take risk in the pursuit of profit.
5. Failure to embed ERM best practices from the top all the way down.
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Rawle Mitchell
July 2011
Regulatory Impact on ERM
ERM must be part of the culture - accepted, expected and practiced at
the highest levels and down through the organization - if it is to help
the organization make better risk-adjusted decisions.
There’s an increased focus on the effectiveness of BOD risk oversight
practices:
1. NYSE’s corporate governance rules already require audit committees
of listed corporations to discuss risk assessment and RM policies.
2. Credit rating agencies, such as S&P, are assessing ERM processes as
part of their corporate credit ratings analysis.
3. More importantly, while business leaders know organizations must
regularly take risks to enhance stakeholder value, effective
organizations recognize strategic advantages in managing risks.
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Rawle Mitchell
July 2011
Regulatory Impact on ERM
4. Signals from some regulatory bodies now suggest that there may be
new regulatory requirements or new interpretations of existing
requirements placed on boards regarding their risk oversight
responsibilities.
5. Legislation has also been introduced in US Congress that would
mandate the creation of board risk committees.
6. The U.S. Treasury Department is considering regulatory reforms that
would require compensation committees of public financial institutions
to review and disclose strategies for aligning compensation with sound
risk-management.
7. July 2009, the SEC issued its first set of proposed rules that would
expand proxy disclosures about the impact of compensation policies on
risk taking and the role of the BOD in the company’s risk management
practices.
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Rawle Mitchell
July 2011
Barriers to Adopting more Strategic
Approaches to RM
1. Ability to feasibly/definitively demonstrate value and ERM ROI
metrics
2. Senior management concerns that ERM processes are too
difficult and/or costly
3. Personnel and financial resources dedicated to RM
4. Personnel skills, expertise and capabilities
5. Products that would enhance RM strategy and capabilities
6. RM technology issues
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Rawle Mitchell
July 2011
Barriers, What Barriers?
Changes that must be made to help firms adopt more
strategic approaches to RM:
1.
2.
3.
4.
Reorganize and reengineer the RM function
Increase internal education
Increase investment and resources in RM capabilities
Implement RM supporting software/technology
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Rawle Mitchell
July 2011
Can ERM Evolve Further?
Some ERM truisms:
1. Firms are using RM more in developing their strategic
goals and objectives.
2. Senior management at many firms are now more aware
than ever of the need to incorporate risk into the
decision making process.
3. Firms are increasing their investment in RM
4. Today RM must deal with the known risks as well as the
unknown and the unknowable.
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Rawle Mitchell
July 2011
Steps to ERM Improvement
1. Integrate strategic planning processes and risk
assessment activities to take advantage of risk
opportunities and consider risk variations across
strategic goals.
2. Reward risk ownership and effective RMAPs, so in this
way ERM is being aligned with the firm’s balanced
scorecard and merit payouts.
 Going forward – companies must focus not only on the
downside of risk but the upside as well.
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Rawle Mitchell
July 2011
What Role Should RMIS Play?
1. RMIS and other technologies today have a large role in managing
risk.
2. Demand for on line, real time risk related calculations with quick
response times means that a new generation of risk systems
architecture is required to cope with such demands.
3. These RMIS have to be event-driven systems with service-oriented
frameworks.
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Rawle Mitchell
July 2011
BOD ERM Role & What Prevents That?
BOD must:
1. Take responsibility for ensuring that the institution has a framework in
place to embed ERM and its constituent parts including risk appetite,
risk roles and responsibilities, etc.
2. Verify that risk and other key personnel are appropriately trained to
fulfill their ERM roles and responsibilities.
3. Insist on receiving regular risk reports and RMAPs.
4. Ensure that corporate objectives are developed in conjunction with
ERM insights.
5. Ensure that executive management conduct table top risk exercises
and submit reports on same to BOD.
6. Ensure that business continuity and disaster recovery plans are
developed, tested and improved regularly.
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Rawle Mitchell
July 2011
Changing Skills Set for the CRO
1. Most progressive institutions have a dedicated senior executive
charged with the responsibility of being the “Risk Champion” at
their organisation.
2. CRO is largely charged with the Risk Champion role.
3. However, the CEO or MD is really the “chief-risk-officer” just as
he/she is the “chief-revenue-officer”.
4. CRO by designation must possess a 360 degree view of the firm.
5. CRO must be multi-faceted in terms of skills set, but in particular,
must be a great communicator and facilitator, very good with
finance, and must thoroughly understand the core nature of the
business.
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Rawle Mitchell
July 2011
There is no time like the present to rethink your
company’s approach to enterprise risk management.
ERM is a process that must be ongoing and
flowing throughout your institution!
Thank You
Email: [email protected] Skype: rawle.mitchell64 Cell: 347-891-9252
1.347.891.9252
[email protected]
Rawle Mitchell
July 2011