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Don’t Overthink Risk Management
Suzanne Hartin
March 2016
2Suzanne Hartin © 2016. All Rights Reserved.
Suzanne Hartin
Recognized Leader in Risk Management
As a senior executive at a top financial services firm, Ms. Hartin is known as an expert
in Enterprise and Operational Risk. Throughout her career she has been accountable
for enterprise level policies, operational management, regulatory compliance, and a
wide variety of risk management activities.
Ms. Hartin has most recently spoken at the Continuity Insights Conference and a Third
Party Risk Management Forum. She has contributed to the development of Community
Bank Board Director Workshops for a major regulatory body and blogs on the topic of
risk management.
Her financial services corporate experience includes Capital One, American Express
and Bank of America, and she sits on the Board of a privately held corporation and a
local non-profit.
With her engaging demeanor and way of translating complex
concepts so they are easy to understand, Ms. Hartin is often
asked to speak on third party risk management, resiliency
and response topics.
3Suzanne Hartin © 2016. All Rights Reserved.
GEAR: Four Critical Steps to Managing Risk
Gather
Report
Address
Evaluate
A strong risk management framework has interlocking processes that
leverage and support each other. To most effectively support company
objectives, these steps must fit together seamlessly.
4Suzanne Hartin © 2016. All Rights Reserved.
Gather: Inventory Relevant Risks
Possible ways to create an inventory
– Scan the external environment
• Applicable regulations
• Newspaper articles about risks in your industry
• Networking with peer companies
– Leverage internal resources and data
• Survey key executives
• Analysis of internal breakdowns and their impacts
Common risks to consider
– Resiliency of technical and business environments
– Third party relationships and services
– Information security
Gather
5Suzanne Hartin © 2016. All Rights Reserved.
Evaluate: Understand the Impact
and Priority of Potential Risks
Step 2
1. For each of the inventoried risks, identify countermeasures in place that reduce either
the likelihood or the impact.
2. After each risk is considered against its countermeasures ,reprioritize the inventory
Evaluate
Step 1
1. Determine likelihood of occurrence for the risks you have
identified
2. Determine the impact of the risks if they should occur
3. Using these two criteria, prioritize this initial list from high to
low inherent risk
6Suzanne Hartin © 2016. All Rights Reserved.
Evaluate, Step 1:
Understand the Impact and Priority of Potential Risks
HighLowMedium
HighMediumLow
Likelihood
Impact
• Determine what high/medium/low means to
you. Is a high likelihood once per year or
once every five or ten years? Is a low impact
$1,000,000 or $10,000,000?
• Consider the inherent risk as though no
countermeasures were in place.
• Those that have some combination of High
and Medium will be the most urgent to
consider further, those with some combination
of Low and Medium will be the least pressing.
• When there is a long list of risks, multiple
items will be in each box and then there will
be a need to determine a more precise
location for each risk in each box – is it higher
or lower in the “high” box, for instance.
• In some cases, it might be more useful to use
a 5-square box, i.e. minimal, low, medium,
high, extreme.
Threats to
data security
Hurricane
threat to Iowa
location
Reputation
risk from
using third
parties
Failure of
network
component
7Suzanne Hartin © 2016. All Rights Reserved.
Evaluate, Step 2:
Understand the Impact and Priority of Potential Risks
HighLowMedium
HighMediumLow
Likelihood
Impact
• For data security, third party and network risk,
countermeasures include:
• A robust information security program
utilizing the latest tools and techniques that
is judged to reduce likelihood but not
impact
• A strong monitoring program for third
parties and their activities on our behalf
which is judged to reduce both potential
likelihood and impact
• Monitoring and redundancy in the network
which is also judged to reduce both
potential likelihood and impact
• There are no countermeasures in place for the
threat of hurricane in Iowa and it is determined
there is no need for any so this risk is accepted
and there is no change.
• In this case, the highest risk is Information
Security, followed by Third Party Risk. These
two might require additional countermeasures if
the remaining risk is above company tolerance.
Threats to
data security
Hurricane
threat to Iowa
location
Reputation
risk from
using third
parties
Failure of
network
component
8Suzanne Hartin © 2016. All Rights Reserved.
Address: Decide What to do About
the Risks You Have Evaluated
Your choices
– Eliminate the risk: stop offering the risky product; move to a less
risky location; stop storing credit card numbers; or whatever it is
that is too risky to do, stop.
– Reduce the risk: if the decision is to continue the business, stay
in the same location , etc, and the current countermeasures
aren’t enough, then design and implement additional ones that
will further reduce the risk
Address
– Accept the risk: if management agrees that the benefit outweighs the risk and all
available countermeasures are already in place, then accept the risk as it is
Making the decision
– It is critical that the decision maker is known and agreed upon and that these decisions
are communicated to all relevant parties
9Suzanne Hartin © 2016. All Rights Reserved.
Report: Share the Data with the
Right People at the Right Times
Right People – know who they are
– Business areas
– Key executives
– Those that need to weigh in on decisions
– Those that need to be informed
– Key committees – executive or risk committees, the Board of Directors
Right Times – what to consider
– More rapidly moving subjects may require weekly or monthly reporting while other items
could be quarterly; consider the cadence of key committee meeting schedules
– Usefulness of conversations at meetings versus email distribution
– Intersection with other reporting such as that done by Internal Audit or report by
regulatory examiners
Report
10Suzanne Hartin © 2016. All Rights Reserved.
Contact Suzanne Hartin
Connect with me on LinkedIn:
• https://www.linkedin.com/in/suzannehartin
Reach out to me for speaking engagements:
• To Boards about Risk Management
• At conferences whether panels or keynotes
• Tailored to specific groups

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Don't Overthink Risk Management by Suzanne Hartin

  • 1. Don’t Overthink Risk Management Suzanne Hartin March 2016
  • 2. 2Suzanne Hartin © 2016. All Rights Reserved. Suzanne Hartin Recognized Leader in Risk Management As a senior executive at a top financial services firm, Ms. Hartin is known as an expert in Enterprise and Operational Risk. Throughout her career she has been accountable for enterprise level policies, operational management, regulatory compliance, and a wide variety of risk management activities. Ms. Hartin has most recently spoken at the Continuity Insights Conference and a Third Party Risk Management Forum. She has contributed to the development of Community Bank Board Director Workshops for a major regulatory body and blogs on the topic of risk management. Her financial services corporate experience includes Capital One, American Express and Bank of America, and she sits on the Board of a privately held corporation and a local non-profit. With her engaging demeanor and way of translating complex concepts so they are easy to understand, Ms. Hartin is often asked to speak on third party risk management, resiliency and response topics.
  • 3. 3Suzanne Hartin © 2016. All Rights Reserved. GEAR: Four Critical Steps to Managing Risk Gather Report Address Evaluate A strong risk management framework has interlocking processes that leverage and support each other. To most effectively support company objectives, these steps must fit together seamlessly.
  • 4. 4Suzanne Hartin © 2016. All Rights Reserved. Gather: Inventory Relevant Risks Possible ways to create an inventory – Scan the external environment • Applicable regulations • Newspaper articles about risks in your industry • Networking with peer companies – Leverage internal resources and data • Survey key executives • Analysis of internal breakdowns and their impacts Common risks to consider – Resiliency of technical and business environments – Third party relationships and services – Information security Gather
  • 5. 5Suzanne Hartin © 2016. All Rights Reserved. Evaluate: Understand the Impact and Priority of Potential Risks Step 2 1. For each of the inventoried risks, identify countermeasures in place that reduce either the likelihood or the impact. 2. After each risk is considered against its countermeasures ,reprioritize the inventory Evaluate Step 1 1. Determine likelihood of occurrence for the risks you have identified 2. Determine the impact of the risks if they should occur 3. Using these two criteria, prioritize this initial list from high to low inherent risk
  • 6. 6Suzanne Hartin © 2016. All Rights Reserved. Evaluate, Step 1: Understand the Impact and Priority of Potential Risks HighLowMedium HighMediumLow Likelihood Impact • Determine what high/medium/low means to you. Is a high likelihood once per year or once every five or ten years? Is a low impact $1,000,000 or $10,000,000? • Consider the inherent risk as though no countermeasures were in place. • Those that have some combination of High and Medium will be the most urgent to consider further, those with some combination of Low and Medium will be the least pressing. • When there is a long list of risks, multiple items will be in each box and then there will be a need to determine a more precise location for each risk in each box – is it higher or lower in the “high” box, for instance. • In some cases, it might be more useful to use a 5-square box, i.e. minimal, low, medium, high, extreme. Threats to data security Hurricane threat to Iowa location Reputation risk from using third parties Failure of network component
  • 7. 7Suzanne Hartin © 2016. All Rights Reserved. Evaluate, Step 2: Understand the Impact and Priority of Potential Risks HighLowMedium HighMediumLow Likelihood Impact • For data security, third party and network risk, countermeasures include: • A robust information security program utilizing the latest tools and techniques that is judged to reduce likelihood but not impact • A strong monitoring program for third parties and their activities on our behalf which is judged to reduce both potential likelihood and impact • Monitoring and redundancy in the network which is also judged to reduce both potential likelihood and impact • There are no countermeasures in place for the threat of hurricane in Iowa and it is determined there is no need for any so this risk is accepted and there is no change. • In this case, the highest risk is Information Security, followed by Third Party Risk. These two might require additional countermeasures if the remaining risk is above company tolerance. Threats to data security Hurricane threat to Iowa location Reputation risk from using third parties Failure of network component
  • 8. 8Suzanne Hartin © 2016. All Rights Reserved. Address: Decide What to do About the Risks You Have Evaluated Your choices – Eliminate the risk: stop offering the risky product; move to a less risky location; stop storing credit card numbers; or whatever it is that is too risky to do, stop. – Reduce the risk: if the decision is to continue the business, stay in the same location , etc, and the current countermeasures aren’t enough, then design and implement additional ones that will further reduce the risk Address – Accept the risk: if management agrees that the benefit outweighs the risk and all available countermeasures are already in place, then accept the risk as it is Making the decision – It is critical that the decision maker is known and agreed upon and that these decisions are communicated to all relevant parties
  • 9. 9Suzanne Hartin © 2016. All Rights Reserved. Report: Share the Data with the Right People at the Right Times Right People – know who they are – Business areas – Key executives – Those that need to weigh in on decisions – Those that need to be informed – Key committees – executive or risk committees, the Board of Directors Right Times – what to consider – More rapidly moving subjects may require weekly or monthly reporting while other items could be quarterly; consider the cadence of key committee meeting schedules – Usefulness of conversations at meetings versus email distribution – Intersection with other reporting such as that done by Internal Audit or report by regulatory examiners Report
  • 10. 10Suzanne Hartin © 2016. All Rights Reserved. Contact Suzanne Hartin Connect with me on LinkedIn: • https://www.linkedin.com/in/suzannehartin Reach out to me for speaking engagements: • To Boards about Risk Management • At conferences whether panels or keynotes • Tailored to specific groups