Risk Management for Asset Managers

Risk
Management
For Asset Managers
September 2011
Author: Pytheas Strategic Advisory,
Pytheas Asset Management &
Harris A. Samaras
Version 06

Contents
Forward 4
Create a SRPMO 5
Adjust Risk 6
Governance for Risk 7
ICAAP for Capital Uplift 9
The Solvency II 10
Counterparty Risk 12
Operational Risk 13
Regulatory Convergence 14
Business Model Adaptation 15
Invest in People 16
ERM Systems & Controls 17
Appendix I – The 3LD Risk Management Model 19
Appendix II – The ICAAP 20
Appendix III – The SREP 21
Appendix IV – The Scope of Risk Management 22
Appendix V – Solvency II, The 3 Pillars 23
Appendix VI – Client Assets (CASS) 24
Appendix VII – The UCTIS IV Directive 25
Appendix VIII – The AIFM Directive 26
Appendix IX – The Mifid II Regulation 27
Appendix X – About Pytheas 30

Forward
Pytheas Asset Management is a leading asset manager for institutions,
individuals and financial intermediaries, worldwide. We focus on global,
regional, developed, and emerging markets, plus a number of specialty
products, including country and sector funds. Our investments combine local
resources with access to global strategies and networks, and we continue to
offer new products in response to an evolving global market and our clients'
evolving needs.
In keeping with the organization's "all-around relationship" approach, our risk
management professionals cooperate intimately with the asset management,
investment banking, industry experts and regional specialists to design risk
management solutions that are most appropriate and effective given industry
characteristics and geographic constraints and imperatives.
This presentation brief highlights the continued evolution and strategic
importance of the risk function for asset management companies.
4
Risk Management
should create value
and be an integral part
of organizational
processes

Create a SRPMO
Create a Strategic Risk PMO (SRPMO) to clarify business and operational
impact for all risk functions.
Focusing risk management on the critical obstacles of protecting and
growing the business in a measurable way gets risk onto the board’s and
senior management’s agendas and focuses attention on material threats that
can really hurt the business.
In today’s rapidly changing environment, companies should repurpose risk
committees (or institute new committees) to concentrate on strategic and
emerging risks in the business climate of each and every year to come. They
should also ensure that the Three Lines of Defence Risk Management Model
(see Appendix I, slide 19) is adhered to, with clear roles and responsibilities
for the business and internal audit functions.
5
Companies
must pay careful
attention to setting and
reviewing their risk
appetite in a more
dynamic manner

Adjust Risk
Set the risk appetite to include more secondary and tertiary factors and
ensure that it is reviewed periodically according to the risk mandates of your
clients and results from ICAAP stress tests (see Appendix II, slide 20).
Asset managers should ensure that there is a clear and tangible articulation
of their company’s tolerance for risk appetite to improve the granularity
according to developing market practices in the industry.
Companies should pay close attention to the direction their peer group is
heading, and be mindful that, eventually, they will be on the hook evidentially
for any documents that are published externally.
Asset managers should also appropriately balance responsibilities between
the business and control functions such as risk, compliance and internal
audit.
6
Companies
should draw upon at
least five to seven
years’ worth of quality
operational data for
their risk modeling and
reverse testing needs

Governance for Risk
Set appropriate governance for investment risk that is consistent with the
company’s risk appetite; involve risk as early in the product life cycle as
possible (see also Appendix IV, slide 22).
As part of industry leading practice, risk should be consulted as early in the
cycle of making all significant business decisions as possible, including those
opening new funds, manufacturing new products or entering new markets.
Products should be brought to market as efficiently as possible without
companies feeling the need to rush particular processes.
Companies should apply particular care and due diligence to products that
are difficult to value, trade in a non-transparent fashion, or are not fungible.
They should consider setting the appropriate level of governance for
investment risk and ensure effective cross-linkage with risk appetite
statements and with operational risk management.
7
Companies
should ensure
effective cross-linkage
with risk appetite
statements and
operational risk
management

Governance for Risk
A scorecard or similar methodology for evaluating product pricing for all new
products and markets should be implemented by asset management
companies in order to ensure that risks are priced appropriately. Ideally, this
should extend to developing more of an Enterprise View for investment risk
with key investment indicators devised and socialized, with attribution
performed on a product-by-product level.
Given greater regulatory focus, companies should place higher weight on the
presence of evidence with OTC trades, or illiquid, complex or leveraged
products.
Multiple and complex investment styles often adopted by asset managers
require the setting of appropriate governance for product risk, investment risk
and market risk.
8
Product risk,
investment risk and
market risk are prime
considerations for
Asset Managers

ICAAP for Capital Uplift
Use ICAAP procedures to optimize the amount of capital uplift needed (as
per Individual Capital Guidance), taking into account the need for robust
evidencing of reverse and normal stress testing (see Appendix II, slide 20).
Companies should carry out comparative studies on what competition is
doing as part of their ICAAP/SREP processes, bearing in mind the type and
combination of style factors that might give the regulator cause for awarding
RMP points or setting elevated ICG uplifts. Revisit unwinding costs and fixed
overhead requirement amounts and define meaningful stress testing to
destruction (killer scenarios). Ensure that your company’s reverse stress-
testing scenarios draw upon at least five to seven years’ worth of quality
operational data if possible. Risk governance arrangements in particular
should provide adequate levels of independent challenge, ideally free from
fund manager or business bias or conflicts of interest. They should be linked
to risk appetite and balance responsibilities between the business and
control functions such as risk, compliance and internal audit (see Appendix
III, slide 21).
9
Management of
capital will differentiate
the winners from the
losers in optimization,
collateral management
or seed capital
decision

The Solvency II
The Solvency II principles-based regime takes effect from 2013; asset
managers with insurance parents or clients will face more frequent and
intensive requests for data for reporting purposes (see Appendix V – slide
23).
Solvency II represents a fundamental review of the capital adequacy regime
for the European insurance industry. Not every asset manager will be
affected by these measures, but those managers with insurer parents are
being pressed to make changes to their systems, and companies with
insurer clients may be faced with more data and reporting requests during
the months ahead.
The data for Solvency II reporting will need to be captured and available to
interrogate at short notice – the end-of-month or quarter-end cycle may not
be sufficient.
10
Under Solvency II,
the end-of-month or
quarter-end cycle
reporting may not be
sufficient

The Solvency II
Companies should consider how to achieve increased look-through of asset
data and the ability to extract additional underlying information.
In addition to sourcing data, asset managers should address issues around
data quality assurance and data governance to ensure they can demonstrate
the validity of any analysis. The issue of data storage and retrieval will also
need to be considered, particularly for firms outsourcing such components.
Given the rapid onset of Solvency II, asset managers who are owned by
insurers should consider how to achieve increased look-through of asset
data and the ability to extract additional underlying information.
11
Under Solvency II,
Asset Managers who
are owned by insurers
should consider how
to achieve increased
look-through of
asset data

Counterparty Risk
Asset managers should upgrade counterparty risk management systems to
enable exposures to be determined by counterparty legal entity and by
product on demand, ideally intraday.
Organizations should upgrade their counterparty risk management programs
to enable them to pre-figure likely risk exposures on demand and to allow
monitoring to be carried out by counterparty and asset class at will.
Companies should also revisit stock lending and collateral management
processes, taking into account new regulatory developments such as the
reintroduction of new short-selling restrictions and new rules around the
handling of client assets e.g., revisions to the CASS rules per the FSA’s
CP10/09 (see Appendix VI – slide 24). Newer regulatory measures, such as
short-selling restrictions, UCITS IV (see Appendix VII – slide 25), the AIFM
Directive (see Appendix VIII – slide 26), European Market Infrastructure
Regulation on OTC derivatives and the proposed Mifid II measures (see
Appendix IX – slides 27 and 28), might require more intelligent approaches
toward mitigating the cost impacts and developing commercial opportunities.
12
New regulatory
measures will require
more intelligent
approaches toward
mitigating the cost
impacts

Operational Risk
Operational risk management needs to determine how regulation is affecting
the adjacent domains, particularly outsourcing and delegation arrangements.
Managing operational risk used to be primarily about managing people,
processes and systems. Given the drive toward greater degrees of
complexity and expected performance, companies are encouraged to
continuously check outsourcing and service level agreement arrangements
with all third parties, especially if the company is actively managing money in
emerging or frontier markets.
This is doubly important when relying upon third parties to value leveraged or
non-transparent products such as interest rate swaps, credit default swaps,
FX swaps/forwards, equity derivatives or inflation/climatic variables. This
activity should include an audit of transfer agents, custodians, fund
administrators and other ancillary functions.
13
Given the new
regulatory measures
risk and compliance
management are
converging for many
Asset Managers

Regulatory Convergence
Companies should complete preparations of KIID/SID documents under
UCITS IV and tighten their risk framework arrangements around their SRRIs,
while remaining vigilant on developments with the AIFM Directive.
ESMA, the body overseeing the technical standards for UCITS, will require
seven levels of risk rating and calculation of the standard deviation of the
fund returns to be evidenced to clients and regulators alike.
Traditional asset managers should not be complacent, as some of AIFM
Directive’s provisions will be used to back-fill the forthcoming UCITS V
regulations. The measures could also result in fewer intended consequences
for traditional firms managing real estate and investment trusts.
14
Asset Managers
should consider
change with regulatory
convergence in mind

Business Model Adaptation
The European Market Infrastructure Regulation being introduced will have a
significant impact on companies employing OTC derivatives for hedging or
as part of their investment strategy.
Heads of risk should accelerate their dialogue with the business and
operations in terms of the potential impacts (both direct and indirect). It is
possible that cost increases could be passed back to the buy-side from extra
capital and collateral arrangements to support the clearing of standardized
asset classes at CCPs.
The notion of principles-based or market-led approaches to regulation is
giving way to a return to outcomes-based approaches and a desire for both
transparency and simplification when it comes to transacting.
15
Transparency and
simplification is a must
when it comes to
transacting

Invest in People
Up-skill resources, investing in people who demonstrate sound capabilities in
regulatory policies and procedures, liaison with board members (including
NEDs) and client facing work in particular.
A critical part of any company’s remit must be to ensure that all members of
its risk team possess the necessary skills to fulfill their roles. However, as
more attention must be diverted to administering governance, responding to
requests for information by regulators and facing up to board members,
NEDs and clients. The risk function needs to be anticipatory, acting more as
a partner in terms of keeping the business out of trouble, not merely policing
or reporting after the fact.
Companies must invest in versatile individuals who can exercise seasoned
judgment, not only on risk matters but also on compliance, legal, internal
audit, business, operations or finance matters.
16
The risk function
needs to be
anticipatory not merely
policing or reporting
after the fact

ERM Systems & Controls
Develop ERM systems and controls, and reinforce workflow management,
management information and data.
Companies should continue to design data taxonomies (e.g., a company-
wide consistent nomenclature behind specifying unique instrument or legal
entity identifiers) to develop master “golden copy” records and dashboard MI
capable of tracking KPIs or KCIs.
Organizations should digitize documentation to support the desire for look-
through and on-demand retrieval, strengthen ring-fencing against fraud and
integrate systems, controls and databases (particularly desktop systems
covering market or investment risk) more effectively with the rest of the
enterprise.
Companies should also take steps to devise an overarching enterprise-wide
risk framework linked to risk appetite, systems needs and required
management processes, plus a road map to drive the same.
17
Companies should
devise an enterprise-
wide risk framework
linked to risk appetite,
systems needs and
required management
processes

The 3LD RM Model
19
§ Promote a strong risk
culture and sustainable risk-
return thinking
§ Portfolio optimization on the
macro and micro level
§ Promote a strong culture of
adhering to limits and
managing risk exposure
§ Ongoing monitoring of
positions and inherent risks
1stLineofDefence
Top Management
& Front Office
§ Combination of watchdog
and trusted advisor; police
limits with “teeth”
§ Understand how the
business makes money –
and actively challenge
initiatives if appropriate
§ Top talent with business
experience engaging with
front office as equals
§ Risk management separate
from risk control
§ Overarching “risk oversight
unit” across all risk types
§ Intraday availability for data
and positions;
comprehensive report at
T+1 6 a.m.
2ndLineofDefence
Risk Management
Function
§ Good understanding of
capital markets, the
business type, and risk
management
§ Top talent within audit – to
challenge the front office
and risk management
function
§ Independent oversight
function – with enforcement
ability (e.g., immediate
fulfillment of findings)
§ Ability to link business and
risk with process and IT
know-how
3rdLineofDefence
Audit

The ICAAP
The ICAAP by the FSA is an important part of the process through which a firm’s Board or equivalent decision-making body is
informed of the ongoing assessment of the firm's risks, how the firm intends to mitigate those risks and how much current and
future capital is necessary having considered other mitigating factors. The ICAAP should therefore be owned and approved by
the firm’s board or equivalent decision-making body.
Medium and larger-sized LLIFs communicate the results of their ICAAP to the FSA by submitting a document which
summarizes the process the firm has gone through to determine the capital it deems necessary to hold (referred to hereafter as
the ‘ICAAP submission’). Through the submission of the FSA019 regulatory return, all LLIFs (including smaller ones) must give
us a quantitative high-level summary of their ICAAP each year. The ICAAP submission or regulatory return should be a
summary of the process the firm has gone through to assess the regulatory capital it should hold. A firm’s senior management
should, on an ongoing basis, satisfy themselves that the firm is, and remains, adequately capitalized. This also applies to
smaller LLIFs which, although they are not usually required to submit us a formal ICAAP (unless requested), should ensure that
they assess the level of capital they should hold on an ongoing basis in a manner which is appropriate to the nature, scale and
complexity of their business (Source: FSA).
See also: ICAAP submissions – Observations for Limited License Investment Firms
Stress and Scenario Testing – feedback on CP08/24
20

The SREP
As per Pillar 2 of the FSA, the Supervisory Board Process has two key elements:
§ Firms should have a process for ensuring that they hold capital consistent with their risk profile and strategy (the Internal
Capital Adequacy Assessment Process, or ICAAP); and
§ Supervisors should review that process and strategies and if they identify weaknesses or deficiencies should take
appropriate prudential measures, including the setting of a higher capital requirement (the Supervisory Review and
Evaluation Process or the SREP).
Through the SREP the FSA seeks to identify any weaknesses or inadequacies requiring a regulatory response in order to
provide the firm with:
§ Individual Capital Guidance (ICG) that reflects the amount of capital that the FSA believes is adequate for its risk profile,
strategy and capital resources;
§ Individual guidance reaffirming or amending any existing liquidity ratios, limits or behavioral concessions; and
§ Resultant prudential or other measures.
See also: FSA – Our Pillar 2 assessment framework
21

Scope of Risk Management
22
The Scope of
Risk Management
Ensuring that all aspects are
considered, bound together by a
common language for Corporate
Governance, Risk Management, and
Assurance, with common Processes,
Culture and Business

Solvency II – Three Pillars
23
§ Balance sheet evaluation
§ Solvency Capital
Requirement (SCR)
§ Minimum Capital
Requirement (MCR)
Pillar 1
Quantitative Requirements
§ System of Governance
§ Own Risk & Solvency
Assessment (ORSA)
§ Supervisory Review
Process
Pillar 2
Qualitative Requirements
§ Annual published solvency
& financial condition report
§ Information provided to the
supervisors
§ Link with IFRS 2
Pillar 3
Disclosure
The Solvency II Directive has been drafted following the advice on
Pillar I issues submitted by CEIOPS in March 2007. While the
Directive has ‘Solvency’ in its title, it explicitly states that capital is not
the only (or necessarily the best) way to mitigate failure. This is
supported by recent CEIOPS studies of insurer failure and ‘near
misses’ which found the primary causes of failure were poor
management and inappropriate risk decisions, rather than capital
inadequacy per se.
With this greater emphasis on risk management, the proposal
compels (re)insurers to instigate governance and risk management
functions and policies as the basis for ensuring adequate solvency
continuously. The Directive stipulates that solvency capital
calculations, whether based on the standard formula or an internal
model, should be aligned to the specific risk profile of the
undertaking. The standard formula categorizes risks into modules for
capital purposes with an allowance for aggregation and
diversification across the modules. An internal model would reflect a
firm’s risk profile and management approach more precisely, and the
sophisticated modeling of risk interactions is highly useful for ongoing
management. However, this presents a more significant
implementation challenge and will need regulator approval.

Client Assets (CASS)
The client asset specialist unit was specifically created by the FSA to provide confidence in the UK regulatory regime’s ability to
deliver adequate protection of client money and safe custody assets (client assets).
The Client Asset Unit’s mission is to help minimize the risk of financial loss from control failings and mitigate the damaging
effects of such potential failures on consumers, firms and the FSA.
The Client Asset Unit has the following key objectives:
§ Improve client asset risk identification, assessment and mitigation
§ Increase firm compliance with the Client Asset Sourcebook (CASS)
§ Enhance our ability to react promptly to firm failure.
See also: FSA Client Asset & Money Report (January 2010)
The Client Money & Asset Return (CMAR)
Developing effective resolution arrangements for investment banks (May 2009)
Source: FSA
24

The UCTIS IV Directive
The UCITS IV Directive is the fourth European Directive covering
Undertakings for Collective Investment in Transferable Securities (UCITS).
The aim was to establish a single regulatory regime across the European
Union for open-ended investment funds to invest in transferable securities
(such as shares, bonds, etc.) to create wider investment and business
opportunities for investors and asset managers and to define high levels of
investor protection.
The UCITS project allows investment funds that fulfill the requirements of the
UCITS Directive to be freely marketed, under the European passport,
throughout the European Union. The UCITS IV Directive offers certain non-
EU fund managers the opportunity to access the European markets without
being brought into the prospective AIFM Directive(Source: European
Commission).
See also: Directive 2009/65/EU of the European Parliament and of the
Council on UCTIS
25
The five key changes built into the UCITS IV are:
Risk Diversification. No investment can exceed 10% of the
relevant UCITS fund’s NAV, with further restrictions such that
any fund would be required to have not less than 16 separate
investment holdings (the “5-10-40 rule”).
Eligible Assets. UCITS IV had substantively widened the
eligibility criteria to include money market instruments, fund
units, bank deposits and derivatives – it being “desirable that
UCITS [funds] should be permitted to invest in financial
instruments, other than transferable securities, which are
sufficiently liquid”.
Leverage. UCITS IV allows funds to borrow up to 10% of its
NAV on a temporary basis, allowing also synthetic leverage.
Restrictions on the global exposure to derivatives are limited to
the NAV of the fund with further restrictions on single
counterparties and permitted underlying assets.
Liquidity. The UCITS framework requires that the units of any
particular UCITS fund must be redeemable not less than twice
a month. Also investors be allowed to redeem on short notice.

The AIFM Directive
The European Commission’s Directive on Alternative Investment Fund Managers (AIFM) regulates managers rather than funds,
although it has an impact on both. As per the directive only AIFMs established in the EU are able to provide their services and
sell their funds to investors in the bloc. Whether or not the fund is established in the EU does not matter, as long as the
manager running the fund is. In order to get permission to market their funds in the bloc, managers must be authorized by the
regulator in the EU country where they are established. Once a manager is authorized in one EU member state, he/she can sell
his/her funds throughout the EU. Managers based outside the bloc will be prohibited from marketing their funds in the EU,
unless they meet various fiscal and regulatory requirements. Managers based in the EU, who run funds established outside the
EU, are also subject to additional restrictions.
The Directive regulates all alternative investment managers in the bloc who are currently not covered by EU law, meaning that
a whole range of other fund managers – such as those running real estate or commodity funds – are regulated in addition to
hedge fund and private equity managers. AIFMs who manage less than €100 million of assets are exempted from the Directive.
For private equity, this applicability threshold is €500 million (Source: European Commission).
See also: Impact of the proposed AIFM Directive across Europe (October 2009)
Directive 2011/61/EU of the European Parliament and of the Council on AIFMs
26

The Mifid II Regulation
Mifid II (October 2011) is the key piece of regulation that is set to transform the way a range of instruments are traded in
Europe. It aims to update and build on the reforms introduced by the 2007 directive. Transparency is the central theme of the
Mifid rules and the European Commission is determined to ensure that the main rules around transparency in equities are
extended to other products too, including bonds, commodities, derivatives and structured finance.
The Commission plans to overhaul the European clearing market by forcing exchanges to allow clearing houses to access their
clearing flows. The rules will finally put an end to “vertical silos” whereby exchanges restrict access to their downstream
clearing houses thereby enabling them to dominate both the trading and clearing of instruments on their platform. The new
clearing rules will help aid competition in the derivatives industry by allowing upstart derivatives trading platforms access to
existing derivatives clearing pools that are vertically integrated. The rules will also force widely traded derivatives out of the
over-the-counter market and onto trading platforms. The European Commission has pushed ahead with a more stringent
version of its controversial proposal to create an additional trading category, an “organized trading facility”, in a bid to force OTC
trading into the light. Banks will not be able to put their own capital to work in the OTF category, which will make it very difficult
for investment banks, which use their own capital in a variety of ways throughout the business, to implement. Only ad hoc
trading of shares and other instruments will be allowed to take place off a platform.
27

The Mifid II Regulation
European efforts to regulate high speed trading will be covered by the Mifid regulation. The most controversial and confusing of
these is the requirement for firms to operate a “continuous” algo trading strategy during trading hours. This would imply that a
firm would have to continue to trade regardless of the prevailing market conditions. In the meantime, however, algo trading
firms will have to provide local regulators with a description of the nature of their algorithmic trading strategies once a year.
Despite much industry pressure, limits on commodities trading positions are to be enforced although these limits are unlikely to
be set in stone but rather subject to regulatory discretion. Regulators will have the power to limit the ability of an individual or
firm from taking over-large positions if they feel that doing so is damaging to the market. The Commission has allowed for the
creation of a commercial, rather than a mandated, trading tape of record. This will dismay many trading firms that are worried
that the commercial model will lead to multiple trading tapes thereby creating less, rather than more, market transparency and
keeping trading data prices high.
Much of the new texts will be referred to pan-European watchdog the European Securities and Markets Authority to implement.
ESMA will also be given the power to intervene in local markets to enforce the rules and ban certain products or practices. Mifid
will determine how share trading is to be suspended across Europe's trading venues. Earlier versions of the text had suggested
that a trading suspension on one platform ought to trigger a suspension on all platforms. This rule seems to have been refined,
however, and now appears to apply under specific conditions. It does not appear to apply in instances where technical
problems bring down a platform.
28

About Pytheas
Like Pytheas, the ancient Greek explorer, scientist and businessman we
provide access to markets inviting our partners to wander the paths and
explore the places with a partner that possesses, knowledge of
prevailing market dynamics, thorough industry expertise, and above all
keen awareness of geographic idiosyncrasies…
Pytheas is an organization with global outlook, offering a wide range of
sophisticated financial services to companies, governments, institutions,
and individuals.
Considered as one of the world's premier organizations in providing
access to emerging financial markets and economies in transition,
Pytheas services range from advising on corporate strategy and
structure to raising equity and debt capital and managing complex
investment portfolios.
Pytheas' investment management capabilities are among the best in the
industry, offering a wide range of investment products and solutions for
the investment issues faced by our clients throughout the world.
30

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31

Pytheas – Company Pulse
Visit
Pytheas
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32

Pytheas Investors Service
The Pytheas Investors Service was established as a vehicle for capital
and investment to advise Pytheas’ clients on how to shape tomorrow’s
business global map – to be a catalyst for growth, development and
diversification by better positioning Pytheas’ clients in the global markets
and in their quest for excellence.
In close cooperation with the rest of Pytheas’ professional network, it
assists and guides clients to clearly identify and establish appropriate
investment opportunities through in-depth research and analysis of the
world's equities, industries, and markets.
Product experts, country specialists and industry analysts work in close
unison and pool their talent to design, recommend, and, when
appropriate, customize and fine-tune investment strategies that clients
can act on in keeping with their portfolio preferences and imperatives.
The breadth and quality of Pytheas' fundamental research and strategic
advice, combined with its in-depth industry knowledge and geographic
specialization, offer investor clients a wealth of information to evaluate
and prioritize their investment decisions.
33

Copyright©2011PytheasLimited
Disclaimer
The above notes have been compiled to assist you; however, actions
taken as a result of this document are at the discretion of the reader and
not PYTHEAS.
All rights reserved. The material in this publication may not be copied,
stored or transmitted without the prior permission of the publishers. Short
extracts may be quoted, provided the source is fully acknowledged.

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