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GRC FOR CAPITAL MARKETS:
Beyond Corporate Governance
Authored by:
Gary Cable, Director of Program Management, Sapient Global Markets
June 2016
GRC FOR CAPITAL MARKETS: Beyond Corporate Governance2 GRC FOR CAPITAL MARKETS: Beyond Corporate Governance2
3
CONTROLS FRAMEWORKS IN
CAPITAL MARKETS
Underestimating the complexity, speed and
interdependencies of technical environments relied on
by capital market participants puts everyone at risk.
After the “Flash Crash” resulted in the loss of billions
of dollars in a matter of minutes, it became clear that
systemic risk was certainly not limited to exchanges—
and that all financial services firms need to address risk,
both systemic and procedural.
Retaining silos within information and functional
infrastructure hampers transparency and exposes
financial services firms to risk. Yet these silos remain,
reinforcing the need for a comprehensive risk
management framework to assist with identifying,
monitoring, managing and reporting on material and
relevant risks.
Systemic risk is caused by unforeseen events
and dependencies where the failure of a single
entity or application could cause a cascading failure—
and potentially bankrupt or bring down an entire system
or market.
Most capital market firms do a decent job of detecting
market risk at the organizational level, but often come up
short in identifying single points of failure that could
bring down a firm’s entire operations, or that create
policy or operational control gaps across legal entities or
lines of business.
The post-financial crisis world has created continued
pressure on capital markets firms to assess their
operating models and key risk areas relative to the
many regulatory changes that went into effect. However,
regulations themselves do not provide a framework
or a formal process for governance, and regulations
such as Reg SCI are not prescriptive about how such a
framework should be created.
Governance, Risk Management and Compliance (GRC)
is a discipline that aims to synchronize information
and activity in order to operate more efficiently, enable
information sharing, report more effectively and avoid
wasteful overlaps—all of which help organizations
manage systemic risk.
An effective GRC controls framework allows firms to
create a comprehensive approach to manage systemic
and other risk by identifying, documenting and
determining a course of action for remediating any such
risks. It does so by addressing characteristics of people,
process or technology equally.
While GRC is often associated with corporate governance
and policy issues, GRC can be applied to financial
events in the capital markets industry by creating a
controls framework specific to business events and
related risks.
INTRODUCTION
GRC can be applied to
financial events in the
capital markets industry
by creating a controls
framework specific to
business events and
related risks.
GRC FOR CAPITAL MARKETS: Beyond Corporate Governance4
Control frameworks are most effective when they can
be used to quantitatively analyze whether sufficient
controls exist and are consistently applied. This can be
accomplished by leveraging business process modeling
tools and persistent data repositories.
An actionable controls framework needs to identify
key dependencies, capture metrics and map them to
detect control points which are the granular events that
occur during the course of business along with their
checks and balances.
TOOLS FOR CREATING
FRAMEWORKS
Figure 1: A complete view of a GRC framework.
Events &
Controls
Rules
Regulations
Policy
Legal
Entity Line of
Business
(LOB)
Region
Business
Function
Accountable
Group
(People)
Assets &
Liabilities
Systems
and Apps
(Tech)
Data
FLOW
F LOW
5
GETTING STARTED
A controls framework can involve multiple levels of
detail and sophisticated cause and effect relationships
throughout the organization. It should enable a firm
to make an intelligent determination of whether to do
something about a problem or leave it alone, depending
on the risk, cost and potential benefits.
Therefore, the best practice is to set the right scope,
focus on where to get the most return on investment in
relation to controlling high-risk areas and regulatory
issues and create a model that can be replicated and
expanded across the organization. The power comes
from leveraging a basic pattern to analyze a specific
problem in one part of the business and then apply it
iteratively to many parts.
Although building a controls framework can be complex,
most firms would rather proactively find risks instead of
having them detected by the audit committee or external
regulator. There is no real argument as to whether
firms should create a controls framework. Ultimately,
success will lie in how organizations set and manage the
appropriate scope and measure the benefits.
Principles from Enterprise Architecture (EA) can be
effective in establishing the connections between
business processes and functions, technology stacks,
security, people and data via their contextual, conceptual,
logical and physical architectures. EA frameworks, like
The Open Group Architecture Framework (TOGAF), use
business context to define the enterprise and the “why,
what, where, when and how” things are done. Merging
the foundational concepts of EA and GRC can be a very
effective combination in defining a controls framework
and building an effective business reference model.
It is also important to create templates for information
capture and distribution based on the firms’ business
reference model, preferably implemented as a web-
based survey where the data can be consistently defined,
captured and maintained. This approach can equally
be used as a method for distributing, analyzing and
visualizing the controls framework in a collaborative way.
Agile is another method that can be quite valuable.
Once scoping and framing are complete, manageable
sprints of work can take place to capture, analyze and
report out. Firms can then rely on a factory model to
incrementally build out the controls framework iteratively
over time and as needed.
Outside experts can offer a good combination of domain
knowledge and tools to help firms create a rationale
based on industry drivers, risk appetite, short-term
objectives and gaps—and help initiate a model that the
organization can continue to develop.
GRC FOR CAPITAL MARKETS: Beyond Corporate Governance6
AUTHOR: GARY CABLE
About Sapient Global Markets
Sapient Global Markets, a part of Publicis.Sapient, is a leading provider of services to today’s evolving financial and commodity
markets. We provide a full range of capabilities to help our clients grow and enhance their businesses, create robust and transparent
infrastructure, manage operating costs, and foster innovation throughout their organizations. We offer services across Advisory,
Analytics, Technology, and Process, as well as unique methodologies in program management, technology development, and
process outsourcing. Sapient Global Markets operates in key financial and commodity centers worldwide, including Boston, Calgary,
Chicago, Düsseldorf, Frankfurt, Houston, London, Los Angeles, Milan, New York, Singapore, Washington D.C. and Zürich, as well as
in large technology development and operations outsourcing centers in Bangalore, Delhi, and Noida, India.
For more information, visit sapientglobalmarkets.com.
© 2016 Sapient Corporation.
Trademark Information: Sapient and the Sapient logo are trademarks or registered trademarks of Sapient Corporation or its subsidiaries in the U.S.
and other countries. All other trade names are trademarks or registered trademarks of their respective holders.
Sapient is not regulated by any legal, compliance or financial regulatory authority or body. You remain solely responsible for obtaining independent legal, compliance and
financial advice in respect of the Services.
Gary is a member of Sapient Global Markets’ Chicago Leadership, defining and
delivering innovative technology solutions, management and strategy to top tier
organizations in the capital markets, banking and insurance. He provides best
practice methodologies to address organizational need, current and target
architectures, operating models and change management practices—balancing
people, process and technology. Gary invented the Lightweight Enterprise
Architecture Framework (LEAF™) which enables business and IT to understand and
agree upon how technology can effectively support the business and determine if
and where change should be made.
7
GRC FOR CAPITAL MARKETS: Beyond Corporate Governance8
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rue du Cendrier 15
1201 Geneva
Switzerland
Tel: +41 (0) 58 206 06 00
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Heritage Plaza
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Houston, TX 77002
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London, E1 6DU
United Kingdom
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Milan
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Italy
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R-Tech Park, Goregaon(E)
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Mumbai, Maharashtra - 400063
India
Tel: +91-22-44764567
Munich
Arnulfstrasse 60
80335 München
Germany
Tel: +49 (0) 89 552 987 0
Noida
(NCR of Delhi)
“Oxygen”, Tower C,
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Noida 201304
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Tel: +91 (120) 479 5000
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40 Fulton Street
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Tel: +1 (212) 206 1005
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Canada
Tel: +1 (416) 645 1500
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Arlington, VA 22201-2909
Tel: +1 (703) 908 2400
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8008 Zürich
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Tel: +41 (58) 206 06 00
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Boston
131 Dartmouth Street
3rd Floor
Boston, MA 02116
Tel: +1 (617) 621 0200
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#137, Bengaluru 560066
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Tel: +91 (080) 410 47 000
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Tel: +1 (403) 444 5574
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GRC FOR CAPITAL MARKETS: Beyond Corporate Governance

  • 1. 1 GRC FOR CAPITAL MARKETS: Beyond Corporate Governance Authored by: Gary Cable, Director of Program Management, Sapient Global Markets June 2016
  • 2. GRC FOR CAPITAL MARKETS: Beyond Corporate Governance2 GRC FOR CAPITAL MARKETS: Beyond Corporate Governance2
  • 3. 3 CONTROLS FRAMEWORKS IN CAPITAL MARKETS Underestimating the complexity, speed and interdependencies of technical environments relied on by capital market participants puts everyone at risk. After the “Flash Crash” resulted in the loss of billions of dollars in a matter of minutes, it became clear that systemic risk was certainly not limited to exchanges— and that all financial services firms need to address risk, both systemic and procedural. Retaining silos within information and functional infrastructure hampers transparency and exposes financial services firms to risk. Yet these silos remain, reinforcing the need for a comprehensive risk management framework to assist with identifying, monitoring, managing and reporting on material and relevant risks. Systemic risk is caused by unforeseen events and dependencies where the failure of a single entity or application could cause a cascading failure— and potentially bankrupt or bring down an entire system or market. Most capital market firms do a decent job of detecting market risk at the organizational level, but often come up short in identifying single points of failure that could bring down a firm’s entire operations, or that create policy or operational control gaps across legal entities or lines of business. The post-financial crisis world has created continued pressure on capital markets firms to assess their operating models and key risk areas relative to the many regulatory changes that went into effect. However, regulations themselves do not provide a framework or a formal process for governance, and regulations such as Reg SCI are not prescriptive about how such a framework should be created. Governance, Risk Management and Compliance (GRC) is a discipline that aims to synchronize information and activity in order to operate more efficiently, enable information sharing, report more effectively and avoid wasteful overlaps—all of which help organizations manage systemic risk. An effective GRC controls framework allows firms to create a comprehensive approach to manage systemic and other risk by identifying, documenting and determining a course of action for remediating any such risks. It does so by addressing characteristics of people, process or technology equally. While GRC is often associated with corporate governance and policy issues, GRC can be applied to financial events in the capital markets industry by creating a controls framework specific to business events and related risks. INTRODUCTION GRC can be applied to financial events in the capital markets industry by creating a controls framework specific to business events and related risks.
  • 4. GRC FOR CAPITAL MARKETS: Beyond Corporate Governance4 Control frameworks are most effective when they can be used to quantitatively analyze whether sufficient controls exist and are consistently applied. This can be accomplished by leveraging business process modeling tools and persistent data repositories. An actionable controls framework needs to identify key dependencies, capture metrics and map them to detect control points which are the granular events that occur during the course of business along with their checks and balances. TOOLS FOR CREATING FRAMEWORKS Figure 1: A complete view of a GRC framework. Events & Controls Rules Regulations Policy Legal Entity Line of Business (LOB) Region Business Function Accountable Group (People) Assets & Liabilities Systems and Apps (Tech) Data FLOW F LOW
  • 5. 5 GETTING STARTED A controls framework can involve multiple levels of detail and sophisticated cause and effect relationships throughout the organization. It should enable a firm to make an intelligent determination of whether to do something about a problem or leave it alone, depending on the risk, cost and potential benefits. Therefore, the best practice is to set the right scope, focus on where to get the most return on investment in relation to controlling high-risk areas and regulatory issues and create a model that can be replicated and expanded across the organization. The power comes from leveraging a basic pattern to analyze a specific problem in one part of the business and then apply it iteratively to many parts. Although building a controls framework can be complex, most firms would rather proactively find risks instead of having them detected by the audit committee or external regulator. There is no real argument as to whether firms should create a controls framework. Ultimately, success will lie in how organizations set and manage the appropriate scope and measure the benefits. Principles from Enterprise Architecture (EA) can be effective in establishing the connections between business processes and functions, technology stacks, security, people and data via their contextual, conceptual, logical and physical architectures. EA frameworks, like The Open Group Architecture Framework (TOGAF), use business context to define the enterprise and the “why, what, where, when and how” things are done. Merging the foundational concepts of EA and GRC can be a very effective combination in defining a controls framework and building an effective business reference model. It is also important to create templates for information capture and distribution based on the firms’ business reference model, preferably implemented as a web- based survey where the data can be consistently defined, captured and maintained. This approach can equally be used as a method for distributing, analyzing and visualizing the controls framework in a collaborative way. Agile is another method that can be quite valuable. Once scoping and framing are complete, manageable sprints of work can take place to capture, analyze and report out. Firms can then rely on a factory model to incrementally build out the controls framework iteratively over time and as needed. Outside experts can offer a good combination of domain knowledge and tools to help firms create a rationale based on industry drivers, risk appetite, short-term objectives and gaps—and help initiate a model that the organization can continue to develop.
  • 6. GRC FOR CAPITAL MARKETS: Beyond Corporate Governance6 AUTHOR: GARY CABLE About Sapient Global Markets Sapient Global Markets, a part of Publicis.Sapient, is a leading provider of services to today’s evolving financial and commodity markets. We provide a full range of capabilities to help our clients grow and enhance their businesses, create robust and transparent infrastructure, manage operating costs, and foster innovation throughout their organizations. We offer services across Advisory, Analytics, Technology, and Process, as well as unique methodologies in program management, technology development, and process outsourcing. Sapient Global Markets operates in key financial and commodity centers worldwide, including Boston, Calgary, Chicago, Düsseldorf, Frankfurt, Houston, London, Los Angeles, Milan, New York, Singapore, Washington D.C. and Zürich, as well as in large technology development and operations outsourcing centers in Bangalore, Delhi, and Noida, India. For more information, visit sapientglobalmarkets.com. © 2016 Sapient Corporation. Trademark Information: Sapient and the Sapient logo are trademarks or registered trademarks of Sapient Corporation or its subsidiaries in the U.S. and other countries. All other trade names are trademarks or registered trademarks of their respective holders. Sapient is not regulated by any legal, compliance or financial regulatory authority or body. You remain solely responsible for obtaining independent legal, compliance and financial advice in respect of the Services. Gary is a member of Sapient Global Markets’ Chicago Leadership, defining and delivering innovative technology solutions, management and strategy to top tier organizations in the capital markets, banking and insurance. He provides best practice methodologies to address organizational need, current and target architectures, operating models and change management practices—balancing people, process and technology. Gary invented the Lightweight Enterprise Architecture Framework (LEAF™) which enables business and IT to understand and agree upon how technology can effectively support the business and determine if and where change should be made.
  • 7. 7
  • 8. GRC FOR CAPITAL MARKETS: Beyond Corporate Governance8 Geneva Succursale Genève c/o Florence Thiébaud, avocate rue du Cendrier 15 1201 Geneva Switzerland Tel: +41 (0) 58 206 06 00 Houston Heritage Plaza 1111 Bagby Street Suite 1950 Houston, TX 77002 Tel: +1 (713) 493 6880 London Eden House 8 Spital Square London, E1 6DU United Kingdom Tel: + 44 (0) 207 786 4500 Los Angeles 1601 Cloverfield Blvd. Suite 400 South Santa Monica, CA 90404 Tel: +1 (310) 264 6900 Milan Sapient Italy S.r.l Viale Bianca Maria 23 20122 Milan Italy Tel: +39-02-00681538 Mumbai Sapient Consulting Pvt. Ltd R-Tech Park, Goregaon(E) 13th Floor, Building 2, Off Western Express Highway Mumbai, Maharashtra - 400063 India Tel: +91-22-44764567 Munich Arnulfstrasse 60 80335 München Germany Tel: +49 (0) 89 552 987 0 Noida (NCR of Delhi) “Oxygen”, Tower C, Ground - 3rd floor Plot No. 7, Sector 144 Expressway Noida 201304 Uttar Pradesh India Tel: +91 (120) 479 5000 New York 40 Fulton Street 22nd Floor New York, NY 10038 Tel: +1 (212) 206 1005 Singapore 158 Cecil Street, #03-01 Singapore 069545 Tel: +65 6671 4933 Toronto 129 Spadina Avenue Suite 500 Toronto, Ontario M5V 2L3 Canada Tel: +1 (416) 645 1500 Washington DC 1515 North Courthouse Road 4th Floor Arlington, VA 22201-2909 Tel: +1 (703) 908 2400 Zürich Seefeldstrasse 35 8008 Zürich Switzerland Tel: +41 (58) 206 06 00 Headquarters Boston 131 Dartmouth Street 3rd Floor Boston, MA 02116 Tel: +1 (617) 621 0200 Bangalore Salarpuria GR Tech Park 6th Floor, “VAYU” Block #137, Bengaluru 560066 Karnataka India Tel: +91 (080) 410 47 000 Calgary 888 3rd Street SW Suite 1000 Calgary, Alberta T2P 5C5 Canada Tel: +1 (403) 444 5574 Chicago 30 West Monroe, 12th Floor Chicago, IL 60603 Tel: +1 (312) 458 1800 Delhi Unitech Infospace Ground Floor, Tower A Building 2, Sector 21 Old Delhi - Gurgaon Road Dundahera, Gurgaon 122016 Haryana India Tel: +91 (124) 499 6000 Düsseldorf Speditionstrasse 21 40221 Düsseldorf Germany Tel: +49 (0) 211 540 34 0 Frankfurt Skyper Villa Taunusanlage 1 60329 Frankfurt Germany Tel: +49 (0)69 505060594 GLOBAL OFFICES