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OPERATIONAL RISK MANAGEMENT




11/16/12                  1
What is Operational Risk?

 The risk of loss resulting from inadequate or failed
   internal processes, people and systems or from
   external events (The Basel II Capital Accord)
 FORMERLY any risk but market and credit risks
 It is NOT a brand new stuff and it is the risk that affects
   all businesses
 Operational risk is inherent in carrying out a process/
   operational activity.



11/16/12                                           2
Classification of Operational Risks

                   High            High       Operational risk events are
                Frequency       Frequency      classified by two factors:
                   Low              High         frequency – how often the
Frequency




                  Impact            Impact         event occurs
                                                 impact – the amount of the
                   Low             Low
                Frequency       Frequency          losses resulting from the
                                                   event
                   Low              High
                  Impact            Impact


                           Impact



            11/16/12                                              3
Classification of Operational Risks

 Generally, operational risk management focuses on only
   two of these event types:
    Low frequency / high impact (LFHI)
    High frequency / low impact (HFLI)
 Why?




11/16/12                                     4
Classification of Operational Risks

 High frequency/low impact events are managed to
   improve business efficiency. These events tend to be
   readily understood and are viewed as ‘the cost of doing
   business’.
 Examples?




11/16/12                                        5
Expected loss verses unexpected loss

 Expected loss is the loss incurred as a bank conducts its
   normal business.
 Can be simply defined as the cost of doing business
 The only way to totally prevent them is to cease doing
   business.




11/16/12                                        6
Expected loss versus unexpected loss

 A bank uses statistical methods to predict its expected
   losses.
 In short, the firm uses past data and experience to
   predict the future.
 A simple method of calculating expected loss is to
   compute the mean (average) of the actual losses over a
   given time and accept this as the likely future level.




11/16/12                                           7
Expected loss verses unexpected loss

 A firm may also attempt to ‘predict’ its unexpected losses
   using statistics, much like the way that is used to predict
   expected losses.
 The problems are the past data may not available and
   therefore to calculate unexpected loss a firm uses:
    available internal data
    external data from other firms
    data from operational risk scenarios



11/16/12                                           8
Operational risk event categories


 The simplest way of understanding operational risk in banks is to
   categorize it as anything but credit risk or market risk.
 However, this is a very broad definition and does not help manage
   operational risk.
 Generally, operational risk events can be subdivided into:
     internal process risk
     people risk
     systems risk
     external risk
     legal risk

11/16/12                                                       9
Internal Process Risk

 Internal process risk is defined as the risk associated
   with the failure of a bank’s processes or procedures.
 During a bank’s day-to-day operations, staff follow preset
   working practices.
 These procedures and policies will include all the
   checks, and controls required to ensure that customers
   are correctly served and the bank remains within the
   laws and regulations by which it is governed




11/16/12                                          10
Internal Process Risks

 Internal process risk events include:
     documentation – inadequate, insufficient or wrong
     lack of controls
     marketing errors
     misselling
     money laundering
     incorrect or insufficient reporting (e.g. regulatory)
     transaction error
 Reviewing and improving a bank’s internal processes as part of
  operational risk management can improve its efficiency. Errors often
  occur when a process is complicated, disorganized or easily
  circumvented, all of which are also inefficient business practices.

11/16/12                                                      11
Risk Management Process Feedback Loop

                       1. Identify, assess and
                            prioritize risks

      6. Revise                              2. Develop
     policies and                           strategies to
     procedures                             measure risk



        5. Test
    effectiveness                       3. Design policies and
     and evaluate                    procedures to mitigate risks
        results
                    4. Implement
                     and assign
                    responsibility

11/16/12                                          12
There are four fundamental steps to managing operational risk, with
each step leading to improvements in management & control quality and
greater economic profit

                                                                                                 REPORTING
                                                                                              • Integrated MIS
                                                                                                reporting
                                                                     MEASUREMENT              • Awareness of
                                                                     • Estimation of annual     exposures
                                                                       losses – cost of       • Knowledge of
                                                                       operational failure      controls quality
                                            PROCESSES
                                                                     • Estimation of VaR –    • Cost benefit analysis
Economic Profit




                                          • Loss data collection
                                                                       risk capital           • Improved risk
                                          • Risk indicator data
                                                                     • Estimation of scores     mitigation and
                    FRAMEWORK               collection
                                                                       representing quality     transfer strategy
                  • Risk strategy,        • Control self-              of internal controls
                    tolerance               assessment
                  • Roles and             • Risk assessment and
                    responsibilities        analysis
                  • Policies and          • Workflow
                    procedures            • Automatic notification
                  • Risk definition and   • Follow up action
                    categorization




                                               Management & Control Quality
The universe of operational risks spans causes, events and
consequences

        CAUSES                   EVENTS              CONSEQUENCES
        Inadequate                                       Legal Liability
    segregation of duties
                                   Internal          Regulatory, Compliance
     Insufficient training          Fraud             & Taxation Penalties

                                   External             Loss or Damage
    Lack of management
                                    Fraud                  to Assets          EFFECTS
        supervision
                                                                              Monetary
                             Employment Practices                              Losses
        Inadequate                                         Restitution
                              & Workplace Safety
    auditing procedures
                              Clients, Products
    Inadequate security                                Loss of Recourse
                             & Business Practices
         measures
                                Damage to
              •                Physical Assets            Write-down

              •              Business Disruption
                              & System Failures
              •                                            Reputation          OTHER
                             Execution, Delivery &                            IMPACTS
       Poor systems
                             Process Management                                Forgone
          design
                                                      Business Interruption    Income
          Poor HR
          policies
Using internal and external loss data can calculate Value at Risk



 INDIVIDUAL                                                   RISK MATRIX FOR                                                                                        LOSS                           VAR               TOTAL LOSS
LOSS EVENTS                                                      LOSS DATA                                                                                       DISTRIBUTIONS                  CALCULATION          DISTRIBUTION




 74,712,345                                                                                                                                                             Frequency
 74,603,709                                                                                                                                                              of events
 74,457,745
 74,345,957
 74,344,576                                                                                                                                                                                          VaR
     •
                                                                                  EMPLOYMENT      CLIENTS,                EXECUTION,      BUSINESS




                                                                                                                                                                                                  Calculator
                                                                                  PRACTICES &   PRODUCTS &   DAMAGE TO    DELIVERY &   DISRUPTION AND
                                                            INTERNAL   EXTERNAL   WORKPLACE       BUSINESS    PHYSICAL     PROCESS         SYSTEM
                                                              FRAUD     FRAUD       SAFETY       PRACTICES     ASSETS    MANAGEMENT       FAILURES      TOTAL
              Corporate Finance       Nu mb er                 36         3           25            36          33           150             2           315




                                                                                                                                                                  0      1     2     3     4
                                      Mea n                  35,459     52,056       3,456        56,890       56,734       1,246          89,678       44,215
                                      Standard Deviatio n     5,694      8,975       3,845         7,890       3,456         245           23,543       6,976




                                                                                                                                                                                                     e.g.,
              Trading & Sales         Nu mb er                 50         4           35            50          46           210             3           441
                                      Mea n                  53,189     78,084       5,184        85,335       85,101       1,869          134,517      66,322
                                      Standard Deviatio n     8,541     13,463       5,768        11,835       5,184         368            35,315      10,464




     •
              Retail Banking          Nu mb er                 45         4           32            45          42           189             3           397
                                      Mea n                  47,870     70,276       4,666        76,802       76,591       1,682          121,065      59,690




                                                                                                                                                                                                    Monte
                                      Standard Deviatio n     7,687     12,116       5,191        10,652       4,666         331           31,783       9,417
              Commercial Bankin g     Nu mb er                 41         3            28           41           37          170               2          357
                                      Mea n                  43,083     63,248       4,199        69,121       68,932       1,514          108,959      53,721
                                      Standard Deviatio n     6,918     10,905       4,672        9,586        4,199         298            28,605       8,476
              Payment & Settlements   Nu mb er                 37         3           26            37          34           153             2           321
                                      Mea n                  38,774     56,923       3,779        62,209       62,039       1,363          98,063       48,349




                                                                                                                                                                                                     Carlo
                                      Standard Deviatio n     6,226      9,814       4,205         8,628       3,779         268           25,744       7,628




     •
              Agency Services         Nu mb er                 44         4           31            44          40           184             2           386
                                      Mea n                  46,529     68,308       4,535        74,651       74,446       1,635          117,675      58,018
                                      Standard Deviatio n     7,472     11,777       5,045        10,353       4,535         321            30,893       9,154
              Asset Manag ement       Nu mb er                 40         3           28            40          36           165             2           347




  167,245                                                                                                                                                                                         Simulation
                                      Mea n                  41,876     61,477       4,081        67,186       67,002       1,472          105,908      52,217




                                                                                                                                                                        Severity
                                      Standard Deviatio n     6,725     10,599       4,541         9,318       4,081         289           27,804       8,238
              Retail Brokerage        Nu mb er                 48         4            33           48           44          198              3          417
                                      Mea n                  50,252     73,773       4,898        80,623       80,402       1,766          127,090      62,660
                                      Standard Deviatio n     8069       12719       5449         11182        4898          347           33365        9886




                                                                                                                                                                                                    Engine
              Insuranc e              Nu mb er                 43         4           30            43          39           179             2           375
                                      Mea n                  45,226     66,395       4,408        72,561       72,362       1,589          114,381      56,394




  142,456                                                                                                                                                                of loss
                                      Standard Deviatio n     7,262     11,447       4,904        10,063       4,408         312           30,028       8,897
              Total                   Nu mb er                 435        36          302          435          399         1,812             24         3,806
                                      Mea n                  45,653     67,021       4,450        73,245       73,044       1,604          115,459      56,926




                                                                                                                                                                                                                   Mean       99th Percentile
                                      Standard Deviatio n     7,331     11,555       4,950        10,158       4,450         315            30,311       8,981




  123,345                                                                                                                                                                                                      Annual Aggregate Loss ($)
  113,342
   94,458
                                                                                                                                                                 0-10   10-   20-   30-   40-
                                                                                                                                                                        20    30    40    50
Composite control assessment/indicator scores can be used to modify
capital figures

                                      CONTROL
                                ASSESSMENT/INDICATOR
             VAR                       SCORE                            CAPITAL




                                      Adjustment for
                                        Quality of
                                      Current Control
                                       Environment

             210                             100                         190
                                                        Current score
                            Previous score         50




                                              0
Linking capital to changes in the quality of internal controls provides an incentive for
desired behavioral change
What does it tell us?




11/16/12                       17
Basel II Approaches on Operational Risk


      •Basic Indicator    •Standardized
        •Standardized     •Foundation IRB
•Advanced Measurement     •Advanced IRB

           •OPERATIONAL   •CREDIT




11/16/12                              18
The Basic Indicator Approach

 Banks using the Basic Indicator Approach must hold
   capital for operational risk equal to the average over the
   previous three years of a fixed percentage (denoted
   alpha) of positive annual gross income.
 Figures for any year in which annual gross income is
   negative or zero should be excluded from both the
   numerator and denominator when calculating the
   average.




11/16/12                                          19
The charge may be expressed as follows:




11/16/12                                20
The Standardized Approach
 In the Standardized Approach, banks’ activities are divided into eight business lines:
  corporate finance, trading & sales, retail banking, commercial banking, payment &
  settlement, agency services, asset management, and retail brokerage.
 Within each business line, gross income is a broad indicator that serves as a proxy
  for the scale of business operations and thus the likely scale of operational risk
  exposure within each of these business lines.
 The capital charge for each business line is calculated by multiplying gross income by
  a factor (denoted beta) assigned to that business line.
 Beta serves as a proxy for the industry-wide relationship between the operational risk
  loss experience for a given business line and the aggregate level of gross income for
  that business line.
 It should be noted that in the Standardized Approach gross income is measured for
  each business line, not the whole institution, i.e. in corporate finance, the indicator is
  the gross income generated in the corporate finance business line




11/16/12                                                                  21
Standardized Approach




11/16/12                       22
Standardized Approach




11/16/12                       23
Mapping Business Lines




                                     ?
11/16/12                        24
Advanced Measurement Approaches (AMA)

 Under the AMA, the regulatory capital requirement will
   equal the risk measure generated by the bank’s internal
   operational risk measurement system using the
   quantitative and qualitative criteria.
 Use of the AMA is subject to supervisory approval.
 A bank adopting the AMA may, with the approval of its
   host supervisors and the support of its home supervisor,
   use an allocation mechanism for the purpose of
   determining the regulatory capital requirement


11/16/12                                        25

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Operational risks

  • 2. What is Operational Risk?  The risk of loss resulting from inadequate or failed internal processes, people and systems or from external events (The Basel II Capital Accord)  FORMERLY any risk but market and credit risks  It is NOT a brand new stuff and it is the risk that affects all businesses  Operational risk is inherent in carrying out a process/ operational activity. 11/16/12 2
  • 3. Classification of Operational Risks High High  Operational risk events are Frequency Frequency classified by two factors: Low High  frequency – how often the Frequency Impact Impact event occurs  impact – the amount of the Low Low Frequency Frequency losses resulting from the event Low High Impact Impact Impact 11/16/12 3
  • 4. Classification of Operational Risks  Generally, operational risk management focuses on only two of these event types:  Low frequency / high impact (LFHI)  High frequency / low impact (HFLI)  Why? 11/16/12 4
  • 5. Classification of Operational Risks  High frequency/low impact events are managed to improve business efficiency. These events tend to be readily understood and are viewed as ‘the cost of doing business’.  Examples? 11/16/12 5
  • 6. Expected loss verses unexpected loss  Expected loss is the loss incurred as a bank conducts its normal business.  Can be simply defined as the cost of doing business  The only way to totally prevent them is to cease doing business. 11/16/12 6
  • 7. Expected loss versus unexpected loss  A bank uses statistical methods to predict its expected losses.  In short, the firm uses past data and experience to predict the future.  A simple method of calculating expected loss is to compute the mean (average) of the actual losses over a given time and accept this as the likely future level. 11/16/12 7
  • 8. Expected loss verses unexpected loss  A firm may also attempt to ‘predict’ its unexpected losses using statistics, much like the way that is used to predict expected losses.  The problems are the past data may not available and therefore to calculate unexpected loss a firm uses:  available internal data  external data from other firms  data from operational risk scenarios 11/16/12 8
  • 9. Operational risk event categories  The simplest way of understanding operational risk in banks is to categorize it as anything but credit risk or market risk.  However, this is a very broad definition and does not help manage operational risk.  Generally, operational risk events can be subdivided into:  internal process risk  people risk  systems risk  external risk  legal risk 11/16/12 9
  • 10. Internal Process Risk  Internal process risk is defined as the risk associated with the failure of a bank’s processes or procedures.  During a bank’s day-to-day operations, staff follow preset working practices.  These procedures and policies will include all the checks, and controls required to ensure that customers are correctly served and the bank remains within the laws and regulations by which it is governed 11/16/12 10
  • 11. Internal Process Risks  Internal process risk events include:  documentation – inadequate, insufficient or wrong  lack of controls  marketing errors  misselling  money laundering  incorrect or insufficient reporting (e.g. regulatory)  transaction error  Reviewing and improving a bank’s internal processes as part of operational risk management can improve its efficiency. Errors often occur when a process is complicated, disorganized or easily circumvented, all of which are also inefficient business practices. 11/16/12 11
  • 12. Risk Management Process Feedback Loop 1. Identify, assess and prioritize risks 6. Revise 2. Develop policies and strategies to procedures measure risk 5. Test effectiveness 3. Design policies and and evaluate procedures to mitigate risks results 4. Implement and assign responsibility 11/16/12 12
  • 13. There are four fundamental steps to managing operational risk, with each step leading to improvements in management & control quality and greater economic profit REPORTING • Integrated MIS reporting MEASUREMENT • Awareness of • Estimation of annual exposures losses – cost of • Knowledge of operational failure controls quality PROCESSES • Estimation of VaR – • Cost benefit analysis Economic Profit • Loss data collection risk capital • Improved risk • Risk indicator data • Estimation of scores mitigation and FRAMEWORK collection representing quality transfer strategy • Risk strategy, • Control self- of internal controls tolerance assessment • Roles and • Risk assessment and responsibilities analysis • Policies and • Workflow procedures • Automatic notification • Risk definition and • Follow up action categorization Management & Control Quality
  • 14. The universe of operational risks spans causes, events and consequences CAUSES EVENTS CONSEQUENCES Inadequate Legal Liability segregation of duties Internal Regulatory, Compliance Insufficient training Fraud & Taxation Penalties External Loss or Damage Lack of management Fraud to Assets EFFECTS supervision Monetary Employment Practices Losses Inadequate Restitution & Workplace Safety auditing procedures Clients, Products Inadequate security Loss of Recourse & Business Practices measures Damage to • Physical Assets Write-down • Business Disruption & System Failures • Reputation OTHER Execution, Delivery & IMPACTS Poor systems Process Management Forgone design Business Interruption Income Poor HR policies
  • 15. Using internal and external loss data can calculate Value at Risk INDIVIDUAL RISK MATRIX FOR LOSS VAR TOTAL LOSS LOSS EVENTS LOSS DATA DISTRIBUTIONS CALCULATION DISTRIBUTION 74,712,345 Frequency 74,603,709 of events 74,457,745 74,345,957 74,344,576 VaR • EMPLOYMENT CLIENTS, EXECUTION, BUSINESS Calculator PRACTICES & PRODUCTS & DAMAGE TO DELIVERY & DISRUPTION AND INTERNAL EXTERNAL WORKPLACE BUSINESS PHYSICAL PROCESS SYSTEM FRAUD FRAUD SAFETY PRACTICES ASSETS MANAGEMENT FAILURES TOTAL Corporate Finance Nu mb er 36 3 25 36 33 150 2 315 0 1 2 3 4 Mea n 35,459 52,056 3,456 56,890 56,734 1,246 89,678 44,215 Standard Deviatio n 5,694 8,975 3,845 7,890 3,456 245 23,543 6,976 e.g., Trading & Sales Nu mb er 50 4 35 50 46 210 3 441 Mea n 53,189 78,084 5,184 85,335 85,101 1,869 134,517 66,322 Standard Deviatio n 8,541 13,463 5,768 11,835 5,184 368 35,315 10,464 • Retail Banking Nu mb er 45 4 32 45 42 189 3 397 Mea n 47,870 70,276 4,666 76,802 76,591 1,682 121,065 59,690 Monte Standard Deviatio n 7,687 12,116 5,191 10,652 4,666 331 31,783 9,417 Commercial Bankin g Nu mb er 41 3 28 41 37 170 2 357 Mea n 43,083 63,248 4,199 69,121 68,932 1,514 108,959 53,721 Standard Deviatio n 6,918 10,905 4,672 9,586 4,199 298 28,605 8,476 Payment & Settlements Nu mb er 37 3 26 37 34 153 2 321 Mea n 38,774 56,923 3,779 62,209 62,039 1,363 98,063 48,349 Carlo Standard Deviatio n 6,226 9,814 4,205 8,628 3,779 268 25,744 7,628 • Agency Services Nu mb er 44 4 31 44 40 184 2 386 Mea n 46,529 68,308 4,535 74,651 74,446 1,635 117,675 58,018 Standard Deviatio n 7,472 11,777 5,045 10,353 4,535 321 30,893 9,154 Asset Manag ement Nu mb er 40 3 28 40 36 165 2 347 167,245 Simulation Mea n 41,876 61,477 4,081 67,186 67,002 1,472 105,908 52,217 Severity Standard Deviatio n 6,725 10,599 4,541 9,318 4,081 289 27,804 8,238 Retail Brokerage Nu mb er 48 4 33 48 44 198 3 417 Mea n 50,252 73,773 4,898 80,623 80,402 1,766 127,090 62,660 Standard Deviatio n 8069 12719 5449 11182 4898 347 33365 9886 Engine Insuranc e Nu mb er 43 4 30 43 39 179 2 375 Mea n 45,226 66,395 4,408 72,561 72,362 1,589 114,381 56,394 142,456 of loss Standard Deviatio n 7,262 11,447 4,904 10,063 4,408 312 30,028 8,897 Total Nu mb er 435 36 302 435 399 1,812 24 3,806 Mea n 45,653 67,021 4,450 73,245 73,044 1,604 115,459 56,926 Mean 99th Percentile Standard Deviatio n 7,331 11,555 4,950 10,158 4,450 315 30,311 8,981 123,345 Annual Aggregate Loss ($) 113,342 94,458 0-10 10- 20- 30- 40- 20 30 40 50
  • 16. Composite control assessment/indicator scores can be used to modify capital figures CONTROL ASSESSMENT/INDICATOR VAR SCORE CAPITAL Adjustment for Quality of Current Control Environment 210 100 190 Current score Previous score 50 0 Linking capital to changes in the quality of internal controls provides an incentive for desired behavioral change
  • 17. What does it tell us? 11/16/12 17
  • 18. Basel II Approaches on Operational Risk •Basic Indicator •Standardized •Standardized •Foundation IRB •Advanced Measurement •Advanced IRB •OPERATIONAL •CREDIT 11/16/12 18
  • 19. The Basic Indicator Approach  Banks using the Basic Indicator Approach must hold capital for operational risk equal to the average over the previous three years of a fixed percentage (denoted alpha) of positive annual gross income.  Figures for any year in which annual gross income is negative or zero should be excluded from both the numerator and denominator when calculating the average. 11/16/12 19
  • 20. The charge may be expressed as follows: 11/16/12 20
  • 21. The Standardized Approach  In the Standardized Approach, banks’ activities are divided into eight business lines: corporate finance, trading & sales, retail banking, commercial banking, payment & settlement, agency services, asset management, and retail brokerage.  Within each business line, gross income is a broad indicator that serves as a proxy for the scale of business operations and thus the likely scale of operational risk exposure within each of these business lines.  The capital charge for each business line is calculated by multiplying gross income by a factor (denoted beta) assigned to that business line.  Beta serves as a proxy for the industry-wide relationship between the operational risk loss experience for a given business line and the aggregate level of gross income for that business line.  It should be noted that in the Standardized Approach gross income is measured for each business line, not the whole institution, i.e. in corporate finance, the indicator is the gross income generated in the corporate finance business line 11/16/12 21
  • 24. Mapping Business Lines ? 11/16/12 24
  • 25. Advanced Measurement Approaches (AMA)  Under the AMA, the regulatory capital requirement will equal the risk measure generated by the bank’s internal operational risk measurement system using the quantitative and qualitative criteria.  Use of the AMA is subject to supervisory approval.  A bank adopting the AMA may, with the approval of its host supervisors and the support of its home supervisor, use an allocation mechanism for the purpose of determining the regulatory capital requirement 11/16/12 25

Editor's Notes

  1. Number of key strokes required to advance slide - 4
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  5. How do we get started: Need Framwork, what is our risk strategy, who will do what, what will be done; Then must define your risks in a way that will be most inutitive for managers. Step II is to set up processes for collecting relavant information and remedial actions. Step III is to take this information and use it to estimate annual losses - cost of doing business, risk exposure (how much you need to set aside in capital reserves) and the quality of internal controls. Finally, we take this information and make it available to decision makers through integrated reports – so managers first becorme aware of their risks and their corresponding controls and can make informed decisions about how to manage these exposure. i.e., understand the costs and benefits of alternate risk mitigation and transfer strategies. (Should I buy a new order processing system, hire one more complice officer, or a consultant to validate my fixed income securities pricing model.) , The first step in the process or operational risk management is to identify roles and responsibilities of the key players, establish policies and procedures that will clarify, document and support the risk management process, formulate a risk strategy and set appropriate tolerances and define and categorize the basic elements that we are attempting to measure. Much more will be said about that last point in a short while. The next step is to develop the means to collect and control loss data and risk indicator data, perform a control self-assessment and risk indicator-based assessment, and to appropriately capture and manage the data that is both input to the process and created along the way. Measuremnt is the next concern, and the system estimates the cost of failure, the required level of risk capital, and those measures are combined with the control self-assessment and the risk indicator scores. Finally, the system provides integrated reporting capabilities which afford greater awareness of exposures, deeper understanding of loss trends, improved strategies for reducing, eliminating, or transfering out operational risk. A cost/benefit analysis capability is also provided.
  6. As the previous slide illustrated, it is important to impose a basic structure on the problem, so as to define risk categories within the context of causes, events, and consequences.
  7. This slide summarizes the process of how the system will: capture data on individual loss events map the data into a risk matrix, where the rows are organizational units, the columns are risk categories, and the entries in each cell correspond to the number of occurrences of events, the mean loss and standard deviation of loss Generate distributions corresponding to the frequency and severity of events for every cell in the matrix Perform a VaR calculation within each cell in the matrix Produce an annual aggregate loss distribution which provides both the expected loss (or cost of doing business) and the unexpected loss (the value at risk at the 99 th percentile–or our one out of one hundred years case! ) Remember, since operational risk events occur in one organizational unit, and since the categories are mutually exclusive, there is no correlation between the individual cells and so the total loss distribution can be summed over the entire matrix to provide an aggregate total annual loss distribution .
  8. In assessing operational risk, it is important to incorporate consideration of the impact of internal controls. This slide points to an example, whereby the VaR calculator determines that $210MM of capital is required. However, we have a risk indicator/ control assessment score that measures the quality of the control environment. By linking changes in these scores, at the individual cell level, the amount of required capital is adjusted upwards or downwards, depending upon the direction and magnitude of the change. The example in this slide illustrates that a 10% improvement in score translates to approximately a ten percent, or $20MM, decline in required capital.
  9. Gross income is defined as net interest income plus net non-interest income. It is intended that this measure should: (i) be gross of any provisions (e.g. for unpaid interest); (ii) be gross of operating expenses, including fees paid to outsourcing service providers; (iii) exclude realized profits/losses from the sale of securities in the banking book; and (iv) exclude extraordinary or irregular items as well as income derived from insurance.