ERM: Are You Thinking BIG Enough? Betty Reed, State of WA Dorothy Gjerdrum, Arthur J. Gallagher STRIMA 2006 September 27, 2006 Agenda Compare the Approach: Traditional RM & ERM Sample Program: WA State Tools & Ideas You Can Use Compare the Approaches Definitions Risk Identification Risk Ranking & Prioritization Risk Response Understanding Risk Across the Organization ERM Defined: “…a process, effected by an entity’s top management and other personnel, applied in strategy setting and across the enterprise, designed to identify potential events that may affect the entity, and manage risks to be within its risk appetite, to provide reasonable assurance regarding the achievement of entity objectives.” Source: Committee of Sponsoring Organizations (COSO) Enterprise Risk Management – Integrated Framework, 2004. ERM & TRM ERM Definition: “A rigorous approach to assessing and addressing the risks from all sources that threaten the achievement of an organization’s strategic objectives. In addition, ERM identifies those risks that represent corresponding opportunities to exploit for competitive advantage.” Tillinghast-Towers Perrin Traditional Definition: “The process of planning, organizing, leading and controlling the activities of an organization in order to minimize the adverse effects of accidental losses on that organization at a reasonable cost.” Essentials of the RM Process ARM 54 Text Insurance Inst. of America Identifying Risk Checklists of Operations & Property Interviews with Key Staff Inspections & Site Visits Records of Incidents & Claims Complaint Forms Budgets, Financial Statements Meeting Minutes Property Records Permits & Contracts ERM Approach to Identifying Risk Interviews with Key Staff Risk Identification Process – Across the Organization Risk Ranking – High/High to Low/Low Performance Measures & Compliance Audits TRM Risk Ranking & Prioritization Primary focus: Reaction to bad press or catastrophic claim(s) Compliance with laws, rules & regs Activities and departments with high losses (frequency or severity or both) Loss runs, complaint forms, etc. ERM – Risk Ranking & Prioritization Focus group identifies: What are the biggest risks our agency is facing? What internal and external events could affect the agency’s mission and the achievement of our goals? Then evaluates and ranks them: To what extent would these potential events impact our goals and what is likelihood that they will happen? Use a rating scale for assessing impact and likelihood (1-3) with 1 low and 3 high Event Identification Differentiates risks and opportunities Events that may have a negative impact represent risks Events that may have a positive impact represent opportunities, which management channels back to strategy setting Event Identification Involves identifying those incidents, occurring internally or externally, that could affect strategy and achievement of objectives. Addresses how internal and external factors combine and interact to influence the risk profile. Risk Register/ Best Practices Risk Mapping 2006 Heat Map Project – Core Business Processes Low Likelihood 5 High Im pact High Likelihood High Im pact 2 Core Business Processes 19 1 Strategic Planning 2 Board Service & Relation (Edu. & Support) 13 3 Business Continuance 16 4 Cash Management 5 Compliance 9 4 6 Contract Services (RFP's) 6 7 Corporate Governance (proxy voting) 8 Custody Operations 9 Data Integrity & Maintenance 11 10 Facility Management 24 Impact 11 Financial Reporting 12 Health & Safety 17 3 20 8 5 13 Human Resource Management 14 Internal Audit 15 Investment Accounting (Portfolio) 16 Legal 7 1 17 Performance Reporting & Measurement 18 Planning/Budgeting/Agency Accounting 19 Portfolio Pricing and Unitization 2 15 21 14 4 20 Risk Management 21 Stakeholder Mgmt. & Communication 22 Technology & Systems 23 Trade Execution 24 Trade Settlements 25 Portfolio Management 14 1 1 Low Im pact 2Low Likelihood 3 Likelihood Low Im pact 4 High Likelihood 5 TRM Risk Response Avoid Retain Transfer ERM Risk Response Quantification of risk exposure Options available: - Accept = monitor - Avoid = eliminate (get out of situation) - Reduce = institute controls - Share = partner with someone (e.g., insurance) Residual risk (unmitigated risk – e.g., unpredictable harm to vulnerable persons) ERM Risk Response Identifies and evaluates possible responses to risk Evaluates options in relation to entity’s risk appetite, cost versus benefit of potential risk responses, and degree to which a response will reduce impact and/or likelihood Selects and executes response based on evaluation of the portfolio of risks and responses ERM Risk Response Control Activities: Policies and procedures that help ensure that the risk responses, as well as other entity directives, are carried out. Occur throughout the organization at all levels and in all functions. Include application and general information technology controls. Understanding Risk Across the Organization – TRM Risk is managed through separate “silos” Lack of full coordination or accountability Risk Silos Law Enforcement Human Resources Regulatory Compiance Transportation Emergency Preparedness University Systems Hospitals & Mental Health Understanding Risk Across the Organization – ERM ERM takes a portfolio view of risk: Risks considered during strategic planning Determine the entity’s “risk appetite” – a high-level view of how much risk the entity is willing to accept Risk tolerance, the acceptable level of variation around objectives, is aligned with risk appetite The State Needs to Manage Its Risk Above the Line As Well As Below Catastrophic risk RISK: Any event that Non-tort litigation risk interferes with the Compliance risk state achieving its strategic objectives Reputational risk Emerging/shifting risk Systemic causes of incidents Financial risk Operational risk Human capital risk 2 2 Liability, Negligence – GL/AL ERM Innovation: Responsibility Who “owns” the risk in your organization? (If the spit hits the fan, who will take a spit bath?) CHALLENGE: What would it look like to have everyone in the organization take ownership? ERM Innovation: Accountability Some of the most successful ERM initiatives have been able to link risk mitigation & management to performance reviews – making managers responsible for risk control & measurement CHALLENGE: What would be a reasonable measurement of compliance? Innovation: Strategic Goals ERM is linked to an entity’s strategic objectives & part of the strategic planning process. It goes beyond the protection of financial assets. CHALLENGE: What would it take to get risk management to that table? How does this work in the real world? State of WA ERM Initiative 2001 Risk Management Task Force Risk Management Executive Order 2002 RM Division moved to OFM 2003 Budgeting through Priorities in Government Policy Level Budget Proposal for SelfInsurance Premium State of WA ERM Initiative 2004 Risk Summits with key agencies 2005 Gov’t Management and Accountability Program – risk focus Strategic Planning must include risk focus ERM introduced by Governor at new executive-level Risk Management Conference State of WA ERM Initiative 2006 Maturity Model adopted to assess and track agency progress Risk Specialist positions created to move agencies toward ERM ERM featured throughout 2006 monthly and quarterly risk publications and training Sample ERM Criteria Risk Manager reports to Director, Secretary 30 or Deputy Director Centralized RM responsibilities assigned as 100% of an FTE (where agency size or risk character warrants) Agency performs annual risk assessment Agency evaluates incidents using varying depth of analysis based on severity of outcome or potential outcome Agency develops practice and process changes, or other corrections based on root cause analysis of identified incidents Moving Toward Enterprise Risk Management Mastery: 6 Mastery 5 4 Enterprise Risk Management Started Most Risk Is Managed at Varying Levels 3 Better Defined Program 2 Part of a Basic Program 1 Pays Premium 31 Action Plan: ■ Use OFM ERM maturity model to measure agency progress. ■ Move agencies forward 20% on continuum by February 2007. Washington State Investment Board Enterprise Risk Management Excerpts from a Presentation to the Washington State Investment Board Washington State Investment Board WSIB Overview The Washington State Investment Board manages investments for 14 separate retirement funds for public employees, teachers, school employees, law enforcement officers, firefighters, and judges. We also manage investments for 19 other public funds that support or benefit industrial insurance, colleges and universities, developmental disabilities, and wildlife protection. Our mission is to invest with integrity, prudence, and skill to meet or exceed the financial objectives of those we serve. As of March 31, 2006 Total assets under management = $69.9 billion Asset Class Market Value U.S. Equity $ 18,144,911,062 International Equity $ 14,049,805,711 Fixed Income $ 21,693,865,409 Private Equity $ 8,836,013,772 Real Estate $ 5,402,592,759 Cash $ 1,804,476,772 33 Washington State Investment Board Enterprise Risk Management (ERM) – What is it? A systematic process for identifying, assessing and prioritizing potential events that may affect the organization Needs support and encouragement from executive management Enterprise-wide participation of event identification and risk response A tool to help management achieve its objectives In short, it’s a process for identifying and managing what may happen that could prevent you from achieving the agency mission 34 Washington State Investment Board ERM Roadmap In 2003 With a strong commitment from the Executive Director, Joe Dear, staff conducted an initial risk assessment which kicked-off the first discussion of enterprise risk management capabilities and effectiveness In 2004 The core of the new risk management strategy was the establishment of an ERM team tasked with defining the ERM key dimensions, principles, core business processes, and common ERM risks In 2005 Risk Director position was created ERM team developed a risk management database system Annual risk assessment questionnaire was developed ERM education was provided to staff In 2006 ERM team benchmarked risk activities against COSO Quantitative evaluation of risk impact and likelihood were added to the database Risk heat map was developed Agency key risks were summarized in a written document 35 Washington State Investment Board ERM Structure Board Governance Audit Committee WSIB Board Executive Management and ERM Team Executive Management Team Deputy Director for Operations (Executive Sponsor) ERM Team ERM Framework and Tools Risk Assessment Risk Management System Board Policy COSO Framework Education Risk Management Principles Risk Reporting 36 Washington State Investment Board WSIB Risk Management Principles – Our guide to track risk events Key Dim ensions Globality Business Integration Human Resources Technology Reputation and Fiduciary Responsibility Investment Management Skill Legal and Compliance Environment Business Continuity These define all aspects of an organization's activities to ensure a comprehensive approach is taken in a risk management program. Principles 15 22 31 28 25 13 37 4 14 12 32 16 23 30 21 10 24 35 36 34 29 33 26 11 19 3 7 9 27 5 18 6 1 2 8 20 17 Adherence to Investment Guidelines Asset Control and Maintenance Cash Management Compliance Credit Risk Management Customer Communications/Reporting Data Integrity & Maintenance Evaluation of Control Effectiveness Fair Dealing Fiduciary Responsibility Financial Accounting Fund/Client Taxation Human Resources Internal Audit Investment Accounting Investment Strategy Research Standards Investment/Benchmark Risk IT Developments IT Security IT Systems Capabilities Legal Enforceability Management Accounting Market Liquidity Model Management & Validation Performance Target Policies & Procedures Product Evaluation & Authorization Project Management Risk Consolidation Risk Limits Risk/Rew ard Analysis Role of Risk Management Group Role of the Board Staff Organization Strategic Planning & Budgeting Trade Management Valuation Core Business Processes 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Each principle defines standards that an organization strives to achieve. Asset Allocation/Strategic Planning Board Service & Relation (Edu. & Support) Business Continuance Cash Management Compliance Contract Services (RFP's) Corporate Governance (proxy voting) Custody Operations Data Integrity & Maintenance Facility Management Financial Reporting Health & Safety Human Resource Management Internal Audit Investment Accounting (Portfolio) Legal Performance Reporting & Measurement Planning/Budgeting/Agency Accounting Portfolio Pricing and Unitization Risk Management Stakeholder Mgmt. & Communication Technology & Systems Trade Execution Trade Settlements Portfolio Management* -Deal Sourcing/Screening -Investment Strategy Research -Tactical Planning/Portfolio Construction -Investment Manager Selection -Broker/Consultant Relation/Mgmnt -Due Diligence -Monitoring -Legal/Deal Completion -Compliance -Trading -Data Management -Manager Termination These core areas represent the business processes w ithin the WSIB's structure. 37 Enterprise Risks 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Bad information Booking error Breaching investment guidelines Breaching regulatory compliance requirements Cash flow risk Stakeholder dissatisfaction Control failure Correlation risk Counterparty Risk Currency convertibility risk Dividend Risk Documentation/contract risk Equity Price Risk Exceeding limits Execution error Fraud Foreign Exchange rate Human resource risk Inadequate information system Inadequate recovery planning Interest rate basis/spread risk IT system failure Legal risk Liquidity risk Missing processes, policies & controls Model/methodology error Money laundering Operational inefficiency risk Other Risks Portfolio concentration - Instrument Processing risk Product Complexity Programming error Regulatory change Reputation risk Rogue trading Security risk (Building, IT & general security) Settlement error Settlement Risk Taxation risk Telecommunication failure Tracking error Underperforming a benchmark These are common types of risks that are used to assess the organization's control structure. Washington State Investment Board Risk Management System Reporting Database Tool to capture errors, incidents, or potential risks on a daily basis Timely resolution of reported items, resulting in minimized business impact Better understanding of the impact incidents/errors have on the overall agency Accurate information on the incidents that are occurring Increased availability of information for management review 38 Washington State Investment Board Annual Risk Assessment Questionnaire Example Core Business Process Principle * 17 Pricing & Unitization CTF and Daily Valued Funds Valuation Scale = 1 - 5 Question 1 Question 2 Risks * 1 7 9 18 19 20 22 25 26 28 29 37 What is the likelihood of an error occurring in the pricing or unitization of the CTF and Daily Funds? What is the likelihood an error will occur because of: bad information control failure a counterparty human resource limitations inadequate information system inadequate business recovery planning IT system failure missing process, policies, or controls methodology modeling error operational inefficiencies other risks a breach in security Average Likelihood Question 3 What is the impact to the agency if there is an error in the valuation? *Numbers correspond to ERM Framework Likelihood Scale Impact Scale 2 1 1 1 2 1 2 1 2 3 1 1 1 1.5 5 1 = Low unlikely to occur 1 = Minor impact 3 = Medium might occur 5 = Event is expected to happen 3 = Moderate impact, loss, disruption, 5 = Significant impact, loss, disruption 39 Washington State Investment Board 2006 Heat Map Project – Core Business Processes Core Business Processes Low Likelihood 5 High Im pact High Likelihood 1 Strategic Planning High Im pact 2 Board Service & Relation (Edu. & Support) 2 19 3 Business Continuance 13 4 Cash Management 16 5 Compliance 6 Contract Services (RFP's) 7 Corporate Governance (proxy voting) 9 4 6 8 Custody Operations 9 Data Integrity & Maintenance 11 10 Facility Management Impact 24 11 Financial Reporting 12 Health & Safety 17 3 20 8 5 13 Human Resource Management 14 Internal Audit 15 Investment Accounting (Portfolio) 7 16 Legal 1 17 Performance Reporting & Measurement 2 15 21 18 Planning/Budgeting/Agency Accounting 14 4 19 Portfolio Pricing and Unitization 20 Risk Management 21 Stakeholder Mgmt. & Communication 22 Technology & Systems 23 Trade Execution 1 1 Low Im pact 2Low Likelihood 3 Likelihood Low Im pact 4 High Likelihood 5 24 Trade Settlements 25 Portfolio Management 40 Washington State Investment Board 2006 COSO* ERM Standard – Process & Categories *Committee of Sponsoring Organizations of the Treadway Commission 41 Washington State Investment Board 2006 COSO* ERM Benchmarking Project What we are doing well in relation to the COSO ERM Framework: We have a strong ethical culture and internal environment, a commitment to competence, and a Board that provides oversight We have an established mission with strategic objectives so that all staff are working towards a common goal We have an established process to identify events, assess risk, and respond We have strong control activities Our ERM process is dynamic and constantly changing ensuring that it remains relevant to the business of the agency *Committee of Sponsoring Organizations of the Treadway Commission 42 Washington State Investment Board 2006 COSO ERM Benchmarking Project (cont’d.) What we want to improve on: Be more explicit in our risk management philosophy Establish succinct risk appetite and tolerance levels Analyze likelihood and impact – then assign risk level Assign risk responses into one of four categories Avoidance Reduction Sharing Acceptance Increase staff participation on risk identification Education on risk terminology, risk assessment, and risk response 43 ERM Tools Risk Rating Tool Raise Risk Awareness – Across the Organization Facilitated Discussion of Risk Discussion of the “Upside” of Risk – Opportunities! – and a Wider Discussion Involving Your Community A Simple Risk Rating Tool Risk Assessment Wallet Tool – Maricopa County (AZ) Community College District MIRA Project Risk Assessment Tool Frequency of Occurrence I Catastrophic II Critical III Marginal IV Negligible A. Frequent 1A 2A 3A 4A B. Probable 1B 2B 3B 4B C. Occasional 1C 2C 3C 4C D. Remote 1D 2D 3D 4D E. Improbable 1E 2E 3E 4E Facilitated Discussion of Risk Before you begin: 1. Make a list of risks you currently don’t manage – include those SMEs Make a list of key players and SMEs representing all areas of operation & functionality – Who should be at the table? 3. List the barriers to conducting this discussion 2. ERM Tools Facilitated Discussion of Risk Cross section of personnel Subject matter experts (SMEs) “What’s the worst that could happen?” “What is it that we cannot allow to happen?” What we learn from school shootings – someone always knows that “something’s not right” Upside Risks/Wider View Identify: Current or new projects – your entity Current or new projects – your community Social trends in your community Economic development in your community – is it booming? – faltering? (Within a crisis, there is opportunity for change) RIMS Survey: ERM Success Factors Leadership Change is hard: make it simple & understandable Ownership, commitment, sponsorship (and cross functional) Disciplined & flexible structure Dedicated time & resources Continuous process for feedback & revisions RIMS Survey: Keys to Success Appropriate leadership & exec. sponsorship Phased work plan – especially at the start Dedicate full-time resources & cross functional teams Early, quick, visible “wins” Balance qualitative & quantitative Integrate ERM into key decision-making processes ERM Implementation Steps • Defined process • Assigned responsibilities • Common language • Dedicated resources • ID Leaders • Risk Identification • Risk management policy • Policy guidelines followed across the organization • Risk measurement • Consistent risk reporting Sources: Excerpted from James W. DeLoach, Toronto 2001 • Enterprise-wide risk strategies • Risk measures applied to business performance goals It’s All About the Journey… Remember that risk management is a continuous process, not a one-time event To be truly successful, risk management must become embedded in your organization deeply, with ownership and implementation at every level of the organization “The significant problems we have cannot be solved at the same level of thinking with which we created them.” Albert Einstein Resources RIMS ERM Center of Excellence is evolving at www.rims.org COSO – www.coso.org IIA (Internal Auditors) www.theiia.org Check out the Australian Standard – NZS 4360 at www.riskmanagement.com/au URMIA Journal – multiple articles – www.urmia.org Speaker Contact Info Betty Reed Risk Management Administrator Risk Management Division of Office of Financial Mgmt. State of WA 360.902.7304 [email protected] Dorothy Gjerdrum, ARM-P Executive Director, Public Entity & Scholastic Division Arthur J. Gallagher Broker & Risk Management Services 952.918.3951 [email protected]
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