Category Archives: Operational Risk Management

Operational Risk Management in Banks: Regulatory, Organisational and Strategic Issues (Palgrave Macmillan Studies in Banking and Financial Institutions)

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Complete Guide to Security and Privacy Metrics: Measuring Regulatory Compliance, Operational Resilience, and ROI

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While it has become increasingly apparent that individuals and organizations need a security metrics program, it has been exceedingly difficult to define exactly what that means in a given situation. There are hundreds of metrics to choose from and an organization’s mission, industry, and size will affect the nature and scope of the task as well as the metrics and combinations of metrics appropriate to accomplish it. Finding the correct formula for a specific scenario calls for a clear concise guide with which to navigate this sea of information.

Complete Guide to Security and Privacy Metrics: Measuring Regulatory Compliance, Operational Resilience, and ROI defines more than 900 ready to use metrics that measure compliance, resiliency, and return on investment. The author explains what needs to be measured, why and how to measure it, and how to tie security and privacy metrics to business goals and objectives. The book addresses measuring compliance with current legislation, regulations, and standards in the US, EC, and Canada including Sarbanes-Oxley, HIPAA, and the Data Protection Act-UK. The metrics covered are scaled by information sensitivity, asset criticality, and risk, and aligned to correspond with different lateral and hierarchical functions within an organization. They are flexible in terms of measurement boundaries and can be implemented individually or in combination to assess a single security control, system, network, region, or the entire enterprise at any point in the security engineering lifecycle. The text includes numerous examples and sample reports to illustrate these concepts and stresses a complete assessment by evaluating the interaction and interdependence between physical, personnel, IT, and operational security controls.

Bringing a wealth of complex information into comprehensible focus, this book is ideal for corporate officers, security managers, internal and independent auditors, and system developers and integrators.
COMPLIANCE RISK II
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Managing Operational Risk: Practical Strategies to Identify and Mitigate Operational Risk within Financial Institutions

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Operational risk is the risk of loss from inadequate or failed internal processes, people, and systems or from external events. There are two types of operational risks: catastrophic and non-catastrophic. The vast majority of operational risks are non-catastrophic, i.e., low-loss events that institutions ably contend with every day. Catastrophic operational risks, however, can give rise to losses so extreme that they immediately put the survival of the institution at stake. This book explores the different types of operational risk that threaten financial institutions. After briefly discussing the non-catastrophic operational risks, the author focuses on practical, due-diligence methodologies that institutions can use to identify less-familiar more-lethal catastrophic operational risks before they detonate. Robertson explains that the mitigation and suppression of potentially catastrophic operational risks require an active, human capital intensive inspection program. This book will help organizations develop a program of quality assurance inspections helping to manage operational risk that could prevent the escalating battle against costly, destabilizing, and often destructive operational risks.
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Operational Risk Management: A Practical Approach to Intelligent Data Analysis (Statistics in Practice)

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Operational Risk. The Regulatory Requirements and Management Process

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Project Report from the year 2015 in the subject Business economics – Business Management, Corporate….
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Operational Risk. The Regulatory Requirements and Management Process

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COMPLIANCE RISK II
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Remedial Compliance: Define Compliance Or Compliance Risk

At Compliance Consultant we get a number of enquiries every month concerning new applications for Authorisation regarding the Part IV permissions needed and the role of Compliance in the application process and beyond.

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There is often a misunderstanding about the role of compliance consultants and the internal role of compliance functions, so we thought we would close off a few of those and cover the top levels of regulatory compliance expectations in the UK Financial Services world and concerning the Financial Conduct Authority (FCA) regulatory compliance guidelines.

First of all, the definition of compliance is technically “the action or fact of complying with a wish or command”. This is not the most helpful definition of compliance regarding financial services regulatory compliance, so we must look to the echelons of the industry to provide a definition of compliance that is more suitable for our purpose, operation and outcome.

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Techtarget.com (the online news and strategy site) define regulatory compliance as “Regulatory compliance is an organization’s adherence to laws, regulations, guidelines and specifications relevant to its business. Violations of regulatory compliance regulations often result in legal punishment, including federal fines.”

Wickipedia defines it as “Regulatory compliance describes the goal that organisations aspire to achieve in their efforts to ensure that they are aware of and take steps to comply with relevant laws and regulations.”

As we can see there is little distinction between the term “Compliance” and the very real meaning of “Compliance Risk“. The risk of non-compliance is a very real threat and can be significant in both terms of cost, management time as well as reputation and remedial compliance actions to rectify the errors or failure of process. This is the main area that we at Compliance Consultant get involved in as we help clients achieve significant and sustainable improvement in their quality performance, customer satisfaction, and regulatory compliance projects.

Perhaps the most accurate and representative definition, although primarily focused on Banking is from the Basel Committee on Banking Supervision, which in 2005 described Compliance risk as: “the risk of legal or regulatory sanctions, material financial loss, or loss to reputation a firm [bank] may suffer as a result of its failure to comply with laws, regulations, rules, related self-regulatory organisation standards, and codes of conduct applicable to its [banking] activities (together, ‘compliance laws, rules and standards’).”

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Understandably, the ‘compliance laws, rules and standards’ actually get revised and updated by the FCA under their authority from the Financial Services and Markets Act 2000 (and it’s various amendments and supporting legislation like the Regulated Activities Order ‘RAO’). There are other influences such as the Prudential Regulatory Authority which supervises banks and a handful of large financial companies, but they work hand in hand with the FCA. Advertising standards, data protection and a raft of other legislation and guidance help the mix to become even more complex and complicated, which is why firms employ consultants like Compliance Consultant to manage discrete special or specialist compliance projects.

The regulatory compliance and risk projects can vary immensely but the overall requirement is usually to provide compliance specialist project resource to resolve or remedy a situation that has arisen. Identification can either be by operational failure, audit or other internal assessment review or regulatory scrutiny as part of a themed visit or ‘deep-dive’ investigation in that sector.

From this you could derive a belief that the FCA are vindictive or aggressively trying to catch out the firms, however the FCA don’t go out of their way to be unreasonable in their expectations and they offer a great deal of guidance and support on their website. The regulator does have a difficult job insomuchas it cannot know every different business model or procedure so it wants to understand the specifics, to ensure that one way of doing things does not cause detriment to the consumer, versus they way they envisage things being done in an ideal world. Saying that, they do expect a certain level of basic compliance from all authorised businesses. The whole rationale of their involvement is centred around every authorised firm and their commitment to treating customers fairly (TCF).

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There are the six TCF outcomes of that commitment according to the FCA.

Outcome 1 – Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture
Outcome 2 – Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly
Outcome 3 – Consumers are provided with clear information and kept appropriately informed before, during and after the point of sale
Outcome 4 – Where consumers receive advice, the advice is suitable and takes account of their circumstances
Outcome 5 – Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect
Outcome 6 – Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

Although this is a very light touch of the overall requirements, there is obviously a lot more to it as you also need to run a very tight ship when it comes to record keeping. The FCA have a central handbook called the “Senior Management Arrangements, Systems & Controls” (SYSC) which contains all of the fundamental areas of business and the rules (and guidance) it needs firms to follow, including risk management, compliance, financial crime, outsourcing and record keeping. Saying you treat your customers fairly is one thing, but you need to be able to evidence it on a consistent basis.office-1209640_1920

How We Can Help

Whether you are a startup bank, have compliance related strategic operational projects, governance, risk and compliance projects, or perhaps banking compliance projects and need additional specialist resource, we will have a solution. We are a niche consultancy and as such only deal with a few select clients at any one time, but we have huge reserves and the ability to react quickly.

We can help you with;
Challenger bank start-up: We are experienced in forming and operationalising bank start ups with great pragmatism and corporate understanding. We can provide the governance and risk structure, the necessary financial stress-testing packages and full range of policies and procedures, as well as marketing assistance and product design.
Benchmarking. To help clients diagnose their quality performance qualitatively and quantitatively, we employ our proprietary benchmarking data to assess factors such as product quality, total costs of quality, resource efficiency, maturity of shop-floor and quality processes, and quality culture.
Developing quality and compliance strategies. Many companies take a short-term approach to address quality costs and imminent non-conformance. Instead, we help clients develop strategies that sustain quality excellence and compliance for the long term.
Delivering compliance and remediation services. Within compliance and remediation, we are able to support a full suite of services using a pragmatic approach and functional experts with deep experience in regulatory requirements. These include helping clients respond quickly to crises and minimise negative impact, as well as identifying and correcting the root causes of quality failures using our proven diagnostic tools.

Contact us today on 0207 097 1434 

or use the contact us page

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