Professional Documents
Culture Documents
appetite frameworks to
strengthen financial institutions
June 2011
implementing robust risk
appetite frameworks to
strengthen financial institutions
June 2011
The financial crisis demonstrated clearly that an effective risk appetite
framework (RAF) is a crucial component of sound enterprise-wide risk
management. Accordingly, both the financial services industry and the
ii regulatory community are devoting a great deal of attention to this
essential governance tool.
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Implementing Robust Risk Appetite Frameworks to Strengthen Financial Institutions
The Board of Directors of the IIF and the Steering to highlighting emerging good practice this Report is also
Committee on Implementation (SCI) are pleased to present offered as the basis for a constructive dialogue with the
this Report to the international financial community. As is global supervisory community on this important issue.
clear from the Report and its annexes, there is widespread The Institute is grateful to member firms for the
recognition of the intrinsic importance of developing commitment of time and resources in developing this
and implementing robust risk appetite frameworks, and Report, in particular the members of the IIF Working Group
tangible progress is being made in this by a number of firms. on Risk Appetite, as well as those firms contributing specific
However, despite solid motivation to get this right, the case-studies. We are extremely grateful to the co-Chairs
challenges are complex and this is still very much ‘work in of the Working Group, Mark Lawrence, Managing Director,
progress’ for many. Mark Lawrence Group and Kevin Nye, Sr. Vice-President,
This Report highlights a number of the specific challenges Royal Bank of Canada for leading the enormous amount of
faced by the industry in the implementation of sound work that has gone into the production of this Report. In
RAFs. Drawing on real-life case studies, the results of a addition, our special gratitude goes to Ernst & Young and
comprehensive industry survey and in-depth interviews, PwC for their contribution in analyzing the survey data (and
the Report brings industry expertise and experience to bear subsequent comments) and identifying themes and insights
on examining how these challenges have been successfully from it.
addressed in a number of leading firms. In doing so, the The lists of IIF Board of Directors, the membership of the
report seeks to identify emerging sound practice as it SCI, and Risk Appetite Working Group members are included
applies to the key stages in the journey towards establishing in the Report.
a sound risk appetite framework.
The key objective of this Report is to offer insights and
specific practical recommendations for the different
stakeholders involved in designing and implementing a
robust and meaningful risk appetite framework. In addition
Preface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii 1
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IIF Board of Directors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Scotiabank . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
2 Chairman
Josef Ackermann*
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Treasurer
Marcus Wallenberg*
Chairman of the Board
SEB
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Goldman, Sachs & Co. Mizuho Corporate Bank, Ltd.
4 Chairmen
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FS Risk Mitsubishi UFJ Financial Group, Inc
Chairmen 7
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Dr. Mark Lawrence Mr. Kevin Nye
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Suncorp Group Finance
• To assess and evaluate current Industry 6. This report from the WGRA includes a combination
practices in the area of risk appetite. of findings and, more important, a number
of practical recommendations as to how to
• To identify the key stages and the technical implement a robust and meaningful risk appetite
and management challenges in the journey framework. Some of the findings with respect to
toward setting—and monitoring adherence the key challenges that firms face in establishing
a risk appetite framework are not necessarily boundaries. It is important to note that our
new. However, the report provides new insights study has shown that leading banks have
and value through its practical recommendations made this linkage in an effective way. Formal
regarding how to address the challenges. involvement of the risk management function
7. The case studies in Annex I cover the in the strategy and business planning processes
development of RAFs at National Australia has resulted in great benefits, which are evident
Bank, Commonwealth Bank of Australia, Royal in some of the case studies supplied.
Bank of Canada, and Scotiabank. While none of • RAFs call for the use of extensive judgment
these firms would claim to have completed the
process, all report that they have made significant
on the part of Boards and management, in
terms of where to begin, where to focus,
11
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progress in implementing effective RAFs. In these and how to engage business leaders. Diverse
1
The strong link between risk culture and the risk appetite framework also was highlighted in the December 2009 IIF report, Reform in the Financial
Services Industry: Strengthening Practices for a More Stable System, in which the following generic definition was provided: “Risk culture can be
defined as the norms and traditions of behavior of individuals and of groups within an organization that determine the way in which they identify,
understand, discuss, and act on the risks the organization confronts and the risks it takes.”
at a simple and uniform set of indicators. decisions about risk in isolation that are then
Supervisors and internal stakeholders handed down as instructions to the businesses.
are encouraged to take a broad and Rather, it is about developing an iterative and
multidimensional view in making assessments collaborative process for creating a framework
in this area. and shared understanding about the boundaries
of acceptable risk—both individually and in
• Clarity regarding the ownership of risk is
aggregate—that forms the basis of continuous
essential. To ensure the broad congruence of
dialogue and decision-making about preferred
business and risk decisions and the overall,
risk/return tradeoffs at all levels in a firm.
12 enterprise-wide risk appetite, business heads
should have visible ownership of risk in their • Stress and scenario testing are important
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areas and incorporate risk explicitly in their components of a risk appetite framework.
Implementing Robust Risk Appetite Frameworks to Strengthen Financial Institutions
business planning. In fact, responsibility for the Specifically, consciously constraining aggregate
articulation and management of risk appetite risks in advance in such a way as to ensure a
within the businesses needs to reside firmly firm’s survival under severe macroeconomic,
and clearly with business unit leaders—not with market and liquidity stress scenarios is at the
their embedded risk management staff—along heart of setting risk appetite appropriately. The
with the ownership of the actual risks in the choice of stress scenarios needs to balance the
businesses. The risk management function need to focus attention on severe outcomes
should own the overall RAF, serve in an while not placing impossible requirements
advisory capacity, and lead the interface with on the businesses. This is a very important
the Board on risk appetite. element of management and Board judgment,
along with assessing the results of the stress
• Communication is a key enabler, both in
tests and deciding on business and strategic
the development of an effective RAF and
adjustments that may be necessary to ensure
in its effective operation. Regular dialogue
that plausible losses under severe scenarios
about risk appetite and evolving risk profiles
would be held to acceptable levels within the
needs to occur among the Board, senior
risk appetite framework. The individual stress
management, the risk management function,
and scenario testing capabilities of firms vary
and the businesses. This dialogue needs to
widely today, and our work has shown that
encompass the development and evolution of
firms are currently taking diverse approaches
the framework itself as well as the risks that
to using these tools for determining risk
are being taken throughout the businesses
appetite. Specifically, some firms are using
and the extent to which these (individually
extensive stress and scenario testing in a very
and collectively) conform to the overall risk
fundamental way in the determination of
appetite. There is also significant value to be
their risk appetite, whereas others are using
gained from communicating risk principles to
these tests only to “sense-check” their overall
broad employee audiences. The promulgation
risk appetite, or (in some cases) not at all.
of agreed-upon key risk appetite themes needs
Consequently, this is a challenging area in which
to come from the top, and professionals within
Industry practices are still evolving and further
the risk management function can also act on
guidance is needed, but there is agreement that
opportunities to illustrate risk principles and
stress testing results need to be incorporated
explain and motivate the boundaries of risk
into the determination of aggregate risk
appetite in day-to-day interactions with front-
appetite in a very fundamental way.
line staff.
10. The report concludes with a set of implications
• Firms that report the most progress in
and recommendations for Board directors, senior
risk appetite practices benefit from strong
management, risk management, and supervisors—
collaboration among their risk management,
the most important of which include these:
finance, and strategy functions. Such
collaboration is fundamentally required during • Board directors should set the framework for
the development of statements of risk appetite risk appetite and put into place mechanisms
and the design of a risk appetite framework, to ensure that decision-making will be
but it is equally important in the day-to- consistently and transparently guided by it.
day operation of an RAF. While the Board But this is only the beginning of the process.
has final responsibility for risk matters, this Effective RAFs involve a highly iterative
is emphatically not about the Board making approach, with ongoing discussions of
risk involving senior management and the • Supervisors are encouraged to take a broad
businesses, and must be rooted in a strong perspective when forming views regarding
risk culture. Engagement and challenge by firms’ commitment to, and progress in, the
the Board are key to achieving the right implementation of RAFs. The process is
balance between rigidity and flexibility in the complex and time consuming, and it touches
risk appetite framework; this is necessary if fundamentally on culture and behaviors in
the framework is to be both workable and a organizations. Assessments of commitment
meaningful source of discipline. and success need to reflect this complexity.
Successful outcomes are not reflected in the
• Senior management should provide visible
support and own the development of the creation of ever more granular limit structures, 13
and no single set of indicators or checklists can
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RAF. Behaviors need to be continually and
than they were able to bear given their capital, purpose of these recommendations was to
Implementing Robust Risk Appetite Frameworks to Strengthen Financial Institutions
liquidity, and risk management capabilities, and promote much more robust risk management and
some took risks that their management and Boards governance frameworks in financial institutions.
did not properly understand or control. Indeed, in 15. Early in the discussion and analytical process
its October 2009 report, Risk Management Lessons that led to the final CMBP report, IIF members
from the Global Banking Crisis of 2008, the identified risk appetite as being of fundamental
Senior Supervisors Group (SSG) highlighted major importance. The CMBP report defined risk appetite
governance challenges at the 20 largest banks in as “a firm’s view on how strategic risk taking can
the most-affected jurisdictions, in particular “the help achieve business objectives while respecting
unwillingness or inability of Boards of Directors constraints to which the organization is subject.”
and senior managers to articulate, measure and A key finding of the CMBP was that putting in
adhere to a level of risk acceptable to the firm.” place a robust risk appetite framework constitutes
The SSG concluded that “a key weakness in an essential component of adequate risk
governance stemmed from … a disparity between management. The CMBP elaborated on a number
the risks that their firms took and those that their of aspects regarding risk appetite, including the
Boards of Directors perceived the firms to be high-level governance aspects of defining and
taking.” Put simply, Boards did not understand implementing a risk appetite framework.
well enough, or properly control in advance,
the risks that their firms were taking. These 16. In 2009 the IIF, recognizing the need to
conclusions are not disputed by the Industry. actively promote the implementation of the
CMBP recommendations, established a Steering
13. Three years after the crisis, largely as a Committee on Implementation (SCI). This
consequence of these conclusions, there is now committee was charged with steering the IIF’s
consensus between supervisors and the Industry efforts on further analysis of key risk management
that a clearly articulated statement of risk appetite implications of the crisis as well as tracking IIF
and the use of a well-designed risk appetite members’ efforts in revising their practices and
framework to underpin decision-making are implementing Industry practices recommendations.
essential to the successful management of risk. In December 2009 the SCI issued its report,
Taken together, such a statement and framework Reform in the Financial Services Industry:
provide clear direction for the enterprise and Strengthening Practices for a More Stable System,
ensure alignment of expectations among the which assessed the progress made by the Industry
Board, senior management, the risk management in implementing and embedding revised risk
function, supervisory bodies, and shareholders. management and governance practices.
In combination with a strong risk culture, they
provide the cornerstone for building the effective 17. Among other issues, the 2009 SCI report focused
enterprise-wide risk management framework that once again on risk appetite, further developing
is essential to the long-term stability of a firm. and discussing the concept and a number of
related issues. The report also provided an
14. In 2008 the Institute of International Finance augmented definition of risk appetite as being “the
formed a high-level Committee on Market Best amount and type of risk that a company is able
Practices (CMBP) to draw key lessons for the and willing to accept in pursuit of its business
financial services industry from the global objectives.” The statement of risk appetite balances
financial crisis that was unfolding at that time. the needs of all stakeholders by acting both as
The CMBP issued a report containing a number a governor of risk and a driver of current and
of key principles and recommendations for the future business activity. It is expressed in both
quantifiable and qualitative terms and covers all supervisory expectations, additional guidance
risks.” In particular, the 2009 report set out an should draw on lessons from firms’ experience
analytical framework for risk appetite and outlined and from the successful practices that are being
a number of key issues in regard to the practical developed globally by many in the Industry. This
implementation of the concept by financial firms. can, in turn, form the basis for a constructive
18. Risk appetite has also received a great deal of dialogue with the global supervisory community.
attention from the regulatory community. In 22. In order to organize the in-depth analysis and
particular, the SSG—which has been the public discussion of risk appetite issues, assess the
sector group most deeply involved in the analysis
of the risk management implications of the crisis—
Industry’s state of practice on the subject, and
learn by leveraging the experience and expertise
15
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has focused extensively on risk appetite issues of a broad range of market participants, the IIF SCI
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the Industry is embracing it, and the principal firms’ leadership of the need to strengthen risk
2
The identification of sound industry practices for risk IT is the subject of a parallel IIF report: Risk IT and Operations: Strengthening Capabilities,
June 2011.
b. The in-depth discussion around the survey of risk considerations into the strategic and
results indicates quite clearly that putting in business plans and more effective risk/reward
place an effective risk appetite framework decision-making across the organization. These
is inextricably linked to the risk culture of benefits can be clearly seen in the case studies
a firm. To be fully effective, the risk appetite attached in Annex I.
framework, together with an appreciation d. There is a high degree of commonality around
of its benefits, needs to be disseminated the most relevant inputs driving the shaping
throughout the institution. Done properly, of a firm’s risk appetite. Most often used is
implementation of a risk appetite framework
18 can act as a powerful reinforcement to a strong
capital capacity, followed by budget targets,
liquidity, and other market constraints and
risk culture in providing a coherent rationale
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and consistent framework for understanding survey data, several firms emphasized that a
risk at all levels. It can never substitute for firm’s overall strategy and financial objectives
proper systems, controls, and limits, but should be considered as a key input.
instead supplements and motivates these and
may even increase compliance. Firms with e. Limits and controls have a central role in
strong risk cultures that provide staff with any well-run organization, but an excessively
guidance for their own behavior and what narrow emphasis on granular limits (or too
to look for and challenge in others are much many of them) can provide false comfort
more effective in the implementation process. to management and supervisors; lead to a
This is especially important when developing mechanical, “tick-box” (or compliance-type)
appetite statements around those risks that are approach; and detract from or undermine this
less quantifiable (e.g., operational risk, risks crucial dialogue. A strong RAF is much more
of legal or regulatory non-compliance, and powerful than limits alone: staff at all levels
reputational risk). It is also clear that risks with any significant responsibility should know
cannot be completely avoided, and aspirational what they need to do and why, rather than
statements relating to “zero tolerance” of merely follow instructions. The overwhelmingly
certain types of risk are less useful than important conclusion from firms’ experiences
detailed guidance to the businesses about how in this area is that developing an RAF is
such risks should be viewed and managed. not about putting in place “tablets of stone”
and creating and implementing a structure
c. While implementing an RAF is challenging, of many hundreds of highly granular limits.
those firms that have made progress are clear It is important that stakeholders, including
that they see tangible benefits resulting supervisors, should recognize this when
from their risk appetite process. While these assessing progress in this area.
benefits are not always apparent at the start,
there is a high degree of consensus among f. The survey shows that a large majority of firms
such firms that the RAF is allowing the Board (70%) are taking a comprehensive view of all
and the senior management to have a more risks across the firm, not merely focusing on
informed discussion of the risks in the business those risks that can be easily measured, and
plan and strategy. Firms reporting the most are using a combination of quantitative and
progress have also established strong linkages qualitative metrics in expressing risk appetite.
between risk issues and strategy, planning, and This reinforces the point that risk appetite does
finance—the last two of these being areas in not mean the creation of a complex, highly
which risk was often not formally considered granular set of limits. That said, at this stage
in the past. These linkages have been put in in the journey the most common transmission
place at both the enterprise-wide and business mechanism for communicating Board-level risk
unit (BU) levels. Such processes may, at least appetite statements throughout the enterprise is
initially, make the resource planning cycle the translation into limits. This in part reflects
longer and more complicated, but this is a the quantifiable nature of some risks and
price well worth paying in return for fostering provides for clear, recognizable boundaries.
a more robust risk culture and a stronger g. Stress testing and stress metrics play a role
awareness throughout the organization. Firms in the risk appetite framework of almost all
at a more advanced stage also highlight the respondents (only one firm stated that they are
benefits deriving from a stronger integration not used). The use of stress tests varies, with
some banks putting them at the center of the
risk appetite setting process, whereas others
use stress tests primarily to “sense-check” their
appetite.
h. A large majority of those responding indicated
that risk appetite is monitored on an ongoing
basis at the group level and that a contingency
plan or escalation procedure is triggered when
a risk appetite metric is exceeded. 19
31. As noted above, the case studies in Annex I are an
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institute of international finance
essential part of this report and clearly illustrate
many of the points listed above. Additionally,
the complete summary findings and data from
the survey are appended to the main body of this
report (see Annex II).
section 2 – Key outstanding challenges in
implementing risk appetite frameworks
risk appetite frameworks, more needs to be done. on narrow compliance with limits and processes.
Implementing Robust Risk Appetite Frameworks to Strengthen Financial Institutions
The survey and discussion reveal there is a degree Nevertheless, even the strongest culture needs to
of commonality in the hurdles firms are facing be supported with good systems, controls, and
and the need for proven practical solutions to limits. It is also necessary to establish a strong
these issues. Section 3 provides a number of link between risk appetite and compensation. At
examples of emerging Industry sound practices the simplest level this can be an assessment of
in addressing these. This section outlines the whether business results and key performance
largest challenges that are proving most difficult indicators (KPIs) have been achieved by operating
to overcome. The chart below shows the most within limits and in accordance with the
relevant survey results in this context. behaviors and culture described and embedded
33. The link with the wider risk culture is of central within the risk appetite. Where this is not the
importance but is also problematic in some case remuneration incentive awards should be
firms. Broad discussion among firms reinforces moderated or adjusted accordingly.
the point that without a strong risk culture 34. Effectively cascading the risk appetite
success on the risk appetite journey is extremely framework throughout the firm and embedding
difficult, if not impossible, while it is easiest to and integrating it into the operational decision-
implement an effective RAF where there is already making process is clearly the largest challenge
a strong culture around risk. However, a number for almost all firms. While most firms have
of respondents cited culture and its link to risk risk policies and risk measures in the form of
appetite as being an important and difficult issue. limits that can easily be cascaded through the
A strong culture implies that staff understand organization, other guidance on risk tends to be
what is required of them with respect to risk and more general and at a higher level. The linkage
0 5 10 15 20 25
Effectively cascading the risk appetite statement through the operational levels
10 7 6
of the organization and embedding it into operational decision making processes
Using the risk appetite framework as a driver of strategy and business decisions 5 5 2 1
2
Achieving sufficient clarity around the concept of risk appetite and some of the 3
7 2 3
terminology used (e.g. difference between risk appetite and risk limits)
How to most effectively aggregate risks from different business units and/or
different risk types, for risk appetite purposes
1 3
between high-level risk appetite principles and setting limits and additional business constraints
the risk policies and metrics guiding day-to-day is also an important challenge. In reality, it is
decision-making needs further development. As necessary to strike the right balance between a
noted, firms that have been most successful in framework on the one hand which is so rigid,
creating an RAF to date have recognized that it constraining and inflexible over time as to be
needs to pervade the organization in the sense unable to sensibly and prudently accommodate
that risk concepts are fully understood by staff the evolution of the businesses and group strategy
at a range of levels and influence behavior as a in a timely fashion, having due regard to the risk
result of being internalized. The benefits of a risk implications, and one on the other hand which is
appetite framework are often much more apparent excessively flexible and too easily substantially 21
to Board members and senior management than changed from one period to the next (perhaps
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institute of international finance
they are to mid-level staff. This raises questions in response to any number of proposed growth
of how best to train and educate staff to enable initiatives), and consequently imposes insufficient
them to perceive the benefits of the new approach discipline on the businesses, lacks continuity,
and also touches upon the desired responsibilities and is difficult for all employees to understand
of management in such training and the way and embrace. Striking this balance correctly
in which the new approaches can or should be requires careful judgment by Boards and senior
supplemented with formal controls and limits. management.
35. The best way of expressing risk appetite in a 37. Many firms have difficulty forging the necessary
way that covers all relevant risks is also proving links between risk appetite and the strategic
a challenge for firms. This is particularly true and business planning processes, though
in respect to risks that are less quantifiable and leading firms have done this successfully. It is
require a more qualitative approach. Once the relatively straightforward to establish an RAF in
process moves beyond traditional credit and the sense of the Board setting out a statement of
market risks—where historical data is abundantly risk preferences that the business then seeks to
available—to focus on reputational, strategic, and translate into a range of limits. There is a growing
operational risks, significant challenges remain. recognition, however, that this is a very narrow
However, it is widely recognized that an RAF concept of risk appetite and that the establishment
cannot be confined to risks that can be easily of actionable guidance at the business unit level
measured. To be meaningful, risk appetite needs to is crucial. The traditional approach of making
take a comprehensive view across a firm, and risk high-level statements and then seeking to turn
appetite statements need to capture and include these into a plethora of granular and not well-
those risks that cannot be easily quantified. The understood limits has been shown to have serious
identification and effective mitigation of such limitations, as it tends to result in risk appetite
risks is a difficult challenge that is not, of course, being seen within the businesses as a remote and
confined to risk appetite. While some firms are sometimes irrelevant part of the risk management
comfortable tracking these risks with qualitative apparatus. As explained further below, risk
indicators, most are making significant efforts to appetite needs to be an integral part of a business.
quantify such risks, through, for example, proxy Its effects need to be pervasive throughout the
measures and use a combination of qualitative and organization, and there needs to be a clear link
detailed quantitative elements in their risk appetite between the RAF and business decisions.
statements. 38. Stress testing, and how it should be effectively
36. Some respondents are finding it difficult to shift incorporated into the risk appetite framework,
the perception that risk appetite is primarily remains an area of uncertainty and evolving
about setting limits. While limits and risk policies practice in the Industry. While it is widely
are important components of an effective risk accepted as being a component of an effective
appetite framework, the more dynamic nature risk appetite framework, there is less consensus
of risk appetite and its role in managing risk, about exactly how stress testing should be
driving strategy, and optimizing return on a much incorporated into a framework. The use of stress
broader basis needs to be ingrained throughout the tests varies widely, with some banks putting them
organization. Ensuring that the RAF is positioned at the center of the risk appetite–setting process,
and perceived internally as a dynamic tool for even as others use stress tests primarily to sense-
shaping the risk profile of the institution, rather check their appetite. As a general observation,
than as merely a dressed-up, “grander” process for the firms that were most affected by the financial
crisis appear to be more advanced in this area, 39. A related issue is how to achieve an appropriate
but further guidance is required for the majority. aggregation at the group level of the levels of
While an important focus of an RAF will be the risks for the different individual businesses
level of risk with which the Board and senior and how to establish relationships between these.
management are comfortable during “business Individual business units need to have a consistent
as usual” conditions, it is equally important to framework for setting their own tolerances
understand and consider the implications of for risk, and these need to be consistent with
extreme but plausible scenarios on the risk profile. the overall enterprise-wide risk appetite, both
The technical and methodological challenges of individually and in aggregate. Although progress
22 stress and scenario testing are well known. In the has been made in this area by a number of firms,
RAF context, Boards, senior management, and no single approach is dominant today. There is
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Implementing Robust Risk Appetite Frameworks to Strengthen Financial Institutions
business units need to ask how the results of stress currently no uniform process for translating high-
tests should be interpreted and what they mean level risk appetite indicators into more specific
for risk profiles and preferences. One particularly measures, such as risk limits and tolerances,
important question in this context is the extent and further work is needed in the area of risk
to which Board members and risk professionals aggregation.
are equipped a) to make sense of scenarios that
have potentially very substantial impacts but
low probability and b) to push back against the
pressures from the business that are curtailing
apparently profitable lines of business.
Section 3 – emerging sound practices in
overcoming the challenges
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with firms to identify ways in which the principal constructively challenge behaviors or decisions of
3
Appendix III of the December 2009 IIF report, “Reform in the Financial Services Industry: Strengthening Practices for a More Stable System,” provides a
background discussion around the concept, importance, and key impacts of risk culture.
45. Given these close links, the practical steps for 3.2 “Driving Down” the Risk
getting the culture of risk appetite right are similar
to those for getting overall risk culture right.
Appetite into the Businesses
Overall, firms report that they know when they 46. Effective internal communication that makes risk
are making progress when references to risk and appetite directly relevant to employees in the
risk appetite become a normal part of day-to-day business units is seen as a major challenge by
discourse about the business. all participating banks. A variety of approaches
have been taken, but no clear consensus has yet
Overall Lessons: emerged about how to do this most effectively.
24 This remains very much work in progress, even for
• There needs to be a demonstrable commitment the leading banks.
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Implementing Robust Risk Appetite Frameworks to Strengthen Financial Institutions
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correspond to the Target Rating set for is a strong consensus that it is very important
different parts of the business. planning: “The integration of the risk appetite
Implementing Robust Risk Appetite Frameworks to Strengthen Financial Institutions
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estimates are made of the potential impact of
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identify concerns such as implementation and/
risk appetite statement or, sometimes, an initial, on a more informed basis. There is no uniform
high-level signaling of key risk parameters to approach for translating high-level risk appetite
business divisions. decisions into workable parameters for business
units. In some cases an initial effort is made at
• Use of these guidelines by the business units
translating the high-level statement into metrics
in drafting their own, divisional business and
such as RoE, RWA, and/or net funding needs,
budget plans. In some cases this involves
which are then fed into the businesses. In general,
the creation of local risk appetite statements.
however, it is recognized that the process needs to
In others it involves the articulation of a
involve a combination of breaking down the high-
risk “posture” that indicates whether risk is
level aspirations into measurable dimensions and
expected to increase, decrease, or remain
business units formulating their bottom-up plans
constant in the business unit.
in a consistent form, allowing the appropriate
• Ensuring that, whatever the form of the local consistency checks to take place.
plan, it embeds and is fully consistent with the
74. The final stage in the iterative process may involve
high-level risk appetite statement or principles.
changing either aspects of the business plans or
• Individual and aggregated assessment at the of the overall risk appetite—but if the latter, this
group level of proposed business and budget is done on a properly informed basis in order to
plans and comparison with the group risk create the needed alignment between the two that
appetite. has often been missing in many institutions in the
• Revision and amendment as appropriate of past. The fact that such decisions are made on a
divisional level plans and budgets—or, in some properly measured and informed basis, and within
cases, group risk appetite. a formal and robust governance framework, is the
key to ensuring that the risk appetite framework
72. In some cases the formal planning process, rather
strikes the right balance between being unduly
than being wholly “top down,” incorporates a
rigid—and therefore unable to effectively and
significant amount of “bottom up” planning at
prudently accommodate business and strategy
an early stage, starting at the divisional level.
evolution—and excessively flexible, in which case
But in either case, iteration—starting with a
it would fail to create the necessary discipline on
concept of risk appetite business planning
the business.
aggregation checking back with the risk
appetite framework and adjusting as necessary—
One bank provided an example of when the explicit
was observed to be the key and an important
consideration of risk appetite in the planning
method to creating essential alignment between
process led to an increase in a business line/asset
the divisional and business unit plans and the
class rather than the imposition of a reduction.
group risk appetite statement. This process also
The group had agreed to a firm-wide risk appetite
builds common awareness of the interaction and
for a certain asset class, and one business unit
tradeoffs between key risk appetite constraints
wanted to increase exposure. This led to a risk vs.
and revenue opportunities. Some firms have found
return discussion, which led to a shift within the
the use of standardized formats for setting out
asset class of increased allocation to the requesting
strategic plans incorporating mandatory sections
business unit, but without an increase in firm-wide
on risk profile and risk appetite to be useful
risk appetite for that asset class. It was reported
mechanisms for ensuring that these issues have the
that “not everyone liked the answer, but they
appropriate prominence in the planning process.
appreciated the openness of the discussion.”
75. The value of a stronger link between risk appetite are the tradeoffs? One firm reported: “This
and business-level planning was summed up [risk appetite] approach allows an intelligent
by CBA, “Building of the consideration of risk discussion of ‘who we are’ and the optimal
appetite into the group’s strategic planning process business mix and balance based on risk and
has been a significant step forward and has given return.” Another said: “getting the Head of
both management and Board transparency either Strategy to recognize and incorporate Risk
to amend the strategy to align with the existing Management personnel into planning decisions
appetite or the appetite to allow for the proposed was big win for us.”
strategy over decisions.”
76. The following have been key factors in building
• Periodic reviews between risk management,
finance, and each business division to discuss
31
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and reinforcing the necessary links with the what is new or growing rapidly, what is
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capabilities in a more central way in their process of stress and scenario tests are acted upon.
of those portfolios (not generally combinable due identified through analysis of limited data is also
to inconsistent scenario assumptions). Limits on a considered. Typically, effects on market and credit
combination of these stress and statistical model risk portfolios and income of asset gathering
results were used as operating controls on the businesses are possible to model more robustly,
businesses. While several units within the bank while volume-based businesses and operational
had gained substantial experience in the generation risks require more judgment.
of macro and market scenarios and the evaluation Scenario impact on P&L, capital, and RWAs are
of their impacts on their respective businesses, evaluated both in absolute terms and with respect
these had not been integrated to develop firm-wide to typical metrics (i.e., Tier 1 ratio). The worst-
scenarios. case scenario of the available set is chosen (along
During the financial crisis, the firm recognized with the complementary firm-wide statistical
the need to adapt its risk appetite framework to model results) for comparison against risk appetite
incorporate stress scenarios alongside its statistical objectives. Of these, perhaps the greatest focus
models and to particularly emphasize protection of is on maintaining a minimum Tier 1 ratio at all
its Tier 1 capital as a risk appetite objective. The times, evaluated for each quarter of the scenario.
period following the Lehman collapse served as a Additionally, the sufficiency of earnings to cover
catalyst and model example for the development potential losses (and the timing of those losses)
of firm-wide scenarios, since it impacted many is considered. Conformance to risk appetite is
of the bank’s business lines and established an tested and reported to senior management monthly
unambiguous level of severity. Subsequently, in the form of a dashboard and commentary,
scenarios covering other potential firm-wide including detailed review of portfolio and business
vulnerabilities have been implemented. losses/performance under the binding scenario.
Development of scenarios typically begins with During the annual planning process, the entire
the identification and prioritization of an area of risk appetite framework is reviewed up to Board
concern, i.e., a potential economic or market crisis, level and business plans are evaluated through
through dialogue among risk managers, economists, the lens of the framework and its metrics. Firm-
and line management. Scenarios are calibrated on wide stress scenarios are considered a particularly
a “how bad could it plausibly get” basis. Based on valuable component of the framework, because
a broad outline of the primary scenario drivers, of the relative ease of describing (and debating)
the firm develop a detailed scenario specification the causal chain by which losses arise and can
describing the evolution over 1–2 years of a few be identified with businesses, portfolios, and risk
dozen broad macro and market variables such as drivers. Consequently, it is considered that scenario-
GDP growth in major markets, interest and FX based metrics offer advantages of transparency and
rates, equity markets, credit spreads, inflation, avoidance of (some) blind spots relative to statistical
and housing prices. Both short-term and long-term measures.
behavior must be modeled to evaluate impact on
portfolios at opposite ends of the liquidity spectrum,
i.e., market vs. credit risks. History and stakeholder
input inform the setting of these parameters,
which are updated periodically (at least once a
year) to ensure that scenario assumptions remain
economically meaningful.
Challenges Associated with Firm-wide Risk For these reasons, although certain capital
Aggregation: measures (e.g., Tier 1 capital adequacy) are
the subject of prominent focus in the overall
88. One of the significant challenges that firms will risk appetite process, it is difficult to robustly
eventually face as they proceed along the risk determine an acceptable level of aggregate
appetite journey is the issue of risk appetite risks using capital measures alone. This is one
aggregation—that being, once individual reason why, in addition to capital and liquidity
businesses have set their own risk appetite measures, leading banks in certain jurisdictions
boundaries, how does an organization decide are increasingly using a variety of stress testing
whether, in aggregate, these boundaries fit within processes, as discussed in detail above. 35
the firm’s overall risk appetite? Or, conversely, if
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90. While Industry practice is clearly still developing
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management, and risk managers in firms. less quantifiable risks. One test of whether the
99. Such an iterative approach results in Board appetite statement and the observance of the
Implementing Robust Risk Appetite Frameworks to Strengthen Financial Institutions
members having other significant challenge boundaries of acceptable risk embodied within the
functions. This challenge is essential to risk appetite framework. Board members should
ensuring that the risk appetite framework is challenge management on the way in which these
neither stultifyingly rigid nor excessively flexible. systems are used to encourage compliance and
These challenge functions include, but are not penalize noncompliance. This may, for example,
confined, to: involve the setting of objective and quantifiable
• Making certain that mechanisms are in behavioral norms or objectives that can be used
place to ensure that new business initiatives, in determining remuneration or promotion or,
transactions, or products are consistent with conversely, as the basis for disciplinary action
the enterprise-wide risk appetite, and that the when necessary. The Board may seek input
risk implications of these are fully understood from the CRO in regards to any risk cultural or
before the activity proceeds. behavioral issues that the Board should consider
in making incentive payment decisions for
• Ensuring that mechanisms are in place to executives.
monitor and manage risks that are not readily
quantifiable—such as reputation and legal 102. Boards have a key role to play in the evaluation
risks—and that their level is consistent with of stress and scenario test results. Members
overall risk appetite. need to satisfy themselves that the stress tests
are conducted rigorously, that the stresses and
• Ensuring that stress testing is undertaken in scenarios strike the right balance between severity
a rigorous and comprehensive way and that and realism, and that the implications have been
the Board is able to assess the results in the properly evaluated across all businesses in the
context of the risk appetite framework (more group. Boards have a fundamental role in deciding
on this below). whether risk appetite needs to be revisited or
100. In general, as this report emphasizes, an effective adjusted in light of the results. Board members
RAF is indissolubly linked to the culture of an also need to ask themselves searching questions
institution. There are no simple measures of risk about their ability to assimilate and respond to
culture, and it is a key responsibility of Boards low-probability but high-impact scenarios. Many
to understand and shape this culture. Experience Board members find this very challenging. Boards
has shown that it can be exceptionally difficult need to be aware of their limitations in this regard
for Boards and supervisors to detect weaknesses and consider carefully whether these are acting as
in risk culture in an otherwise performing firm; a brake on effective decision-making.
in particular, the absence of obvious contra- 103. Finally, Boards should subject their own
indicators cannot be taken as positive evidence operations and processes to constant review.
of a strong culture. Understanding and shaping Every effort should be made to identify, on a
the firm’s risk culture involves setting broad continuous basis, areas in which Board procedures
direction and continual challenging of senior have worked well and not so well and to learn
management to demonstrate how their actions and from mistakes. There should be an annual review
communications are consistent with this and how of how the Board interacts with the management
rewards and penalties are visibly and predictably and business heads. Overall, the Board should
aligned with the firm’s avowed risk culture. Senior have a formal process at least annually for
management should be expected to account for considering whether and how it has made a real
their behaviors, and Board members may find it difference to risk management in the organization.
helpful to find opportunities to interact directly
Recommendations for Senior there is no clear need to have the enterprise-level
RAF as a document that middle management
Management across the enterprise must use. The critical
104. Implementation of an effective risk appetite component is to have a risk appetite framework
framework is highly dependent on visible that helps drive a clear and comprehensive limit
support from senior management, including a structure for the various businesses as well as
bank’s Executive Committee and business leaders. activities and limits that determine the ability of
This includes recognition and acknowledgment middle management to pursue and grow specific
that a clear statement of risk appetite helps drive lines of activity that link back to the enterprise
risk and governance discussions, is integral to risk appetite framework. Line-of-business risk 39
the strategic and business planning discussions, appetite frameworks should not be developed
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institute of international finance
and provides assurance to regulators and rating as simple subsets (or even simple “clones”) of the
agencies that the institution has clear parameters enterprise framework. While there are linkages to
for how much risk it will take on. The following the enterprise framework, the most useful aspects
are the main implications of our investigation for of the business-level frameworks are often quite
senior management: specific to the line of business, reflecting the
105. To be effective it is essential that senior diversity of a firm’s activities, geographic scope, or
management set the tone and lead the discussion regulatory regimes in which it operates.
regarding risk appetite. Senior management 110. Senior management needs to ensure that the risk
must be seen as taking a leadership role in appetite framework includes full consideration
articulating the importance and benefit of risk of and appropriately reflects business strategy.
appetite throughout an organization. This is an It is important that the Board and the market
ongoing responsibility and must be continually understand that the senior management takes risks
emphasized. in areas that are central to its key strategies and
106. Recognition that risk appetite and risk culture businesses and that losses in those areas, while not
are inextricably linked is important, given that positive, are expected and understood as a likely
culture derives from leadership and determines outcome in both normal business conditions and
inter alia, how middle-level managers assimilate under a difficult market/stress scenarios. Smaller
and embed risk appetite. and more peripheral businesses by contrast should
not be a source of significant losses.
107. Creation of an enterprise-wide RAF is an
iterative process involving the Board, senior 111. It is important that senior management
management, and risk management staff. At understands and accepts how the RAF will
the heart of the process is an ongoing dialogue, apply to its activities and impact any initiatives,
and senior management should expect to be growth plans, or acquisitions that may be under
challenged by the Board as to what is being consideration. The strategic planning process
recommended, including risk/return tradeoffs and must include discussions relating to risk appetite
regular close scrutiny and discussion of all aspects and profile. While risk appetite needs to become
of the firm’s risk profile under stressed conditions. a fundamental driver of strategy and of front-line
business decisions, it should be accepted that it
108. It is an absolute requirement that the business will take time and effort to get this to a point at
(and not risk management) take ownership which business unit leaders and risk managers are
and drive the development of line-of-business comfortable with the process.
risk appetite and profile. It must be recognized
that risk appetite does not belong to the risk 112. Business leaders must ensure that risk metrics
management staff and is not simply another way adequately capture and reflect all material
to set limits and constrain business. Business unit risks of their business. These metrics should
risk appetite frameworks are the main vehicle for be meaningful and pertain to their key business
providing guidance and clarity regarding which and risk drivers. Similarly, the businesses are
activities and risks businesses can consider and responsible for putting appropriate controls in
what would be outside of agreed upon appetite. place to effectively manage their risks, so as to
ensure that they do not exceed their defined risk
109. It is important to recognize that while it is helpful appetite.
to have an articulation of risk appetite that can be
used by the Board and all levels of management,
Recommendations for Risk 118. Risk management needs to provide the
appropriate infrastructure and controls to
Management support the ongoing maintenance of the RAF.
113. Development and maintenance of an effective risk This includes comprehensive and timely reporting
appetite framework is a shared responsibility, to senior management and the Board to provide
with risk management staff playing an essential clear reference to the current risk profile and to
role in the process. It is not uncommon for make the framework itself both real and relevant.
risk management to take the lead in building Ongoing reporting of the firm’s risk profile relative
management support and engaging the Board as to the agreed upon risk appetite—and how this is
40 the framework is developed. Similarly, the ongoing changing—and repeated/iterative discussions of
maintenance of a robust framework is heavily
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dependent on risk management to provide good- both “pattern recognition” and acceptance of the
quality reporting of risk metrics to support the framework as a useful tool.
framework and its application. The following are
119. Risk appetite needs to be viewed in the context
the main implications of our investigation for risk
of both normal and stress conditions. Risk
management staff:
management needs to be capable of providing
114. Risk management needs to be actively involved both of these perspectives and facilitating the
at multiple levels in the development of the appropriate discussion at the Board level with
risk appetite framework. It is incumbent upon regard to the potential impact on business strategy
risk management to provide clarity of concept and planning.
and definition and support in understanding
120. It is critical that risk management engage with
the implications of the risk appetite statements
the businesses in the strategy and planning
and metrics as they develop. A lack of clarity in
process to ensure proper alignment between the
definition often leads to confusing and ineffective
enterprise-level statement of risk appetite and those
discussion that can frustrate the participants and
statements created at the business-specific level.
extend the process unnecessarily. In this regard,
it is important that risk management provide the 121. Risk management should be the catalyst
necessary coaching and training to facilitate the and conduit for effective discussion of risk
understanding of risk appetite on an enterprise- appetite between the Board and the businesses
wide basis. by translating what may be at times high-level
statements of risk preference into effective risk
115. An effective RAF covers all risks, and it is
measures and limits appropriately tailored to each
important that risk management work with all
business.
stakeholders in developing the right balance of
appropriate quantitative and qualitative metrics. 122. Risk management must ensure that the RAF is
Recognizing that the appetite for some risks is supported by a suite of risk policies that reinforce
more easily quantified than others, it is important and reflect the risk appetite as articulated. This
that risk management lead the discussion and includes a clear understanding of the process for
development of desired behavior and tolerances dealing with and reporting transactions that may
for less quantifiable risks such as reputation risk. be approved outside of policy boundaries as well
as excesses to approved risk appetite.
116. Risk appetite is an iterative process that requires
perseverance. To that end, the challenges faced 123. Education and communication are areas in which
early in the process are different from those it is vital for risk management to participate on
experienced later. At all stages, it is important for an ongoing basis. It is necessary to effectively
risk management to ensure full engagement by communicate the key elements of the design,
all key stakeholders, including the Board, senior implementation, and maintenance of the risk
management, and risk practitioners. appetite framework to all stakeholders internally
and externally. It also is important that the Board
117. At the same time, risk management must allow
be able to address questions raised by shareholders
the businesses to take charge of the process of
and regulators alike as to the appropriateness
developing line-of-business–level risk appetite
of the nature and quantum of the risks being
statements. This means the business unit leaders
assumed, both individually and in aggregate, and
themselves, not the embedded risk management
how senior management is challenged in this
staff within the business units.
regard.
Section 5 – Implications for supervisors
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task. Instead, the purpose of this section is to dilatory approach or lack of commitment. The
throughout its business units. Individuals with risk culture. Efforts made by firms to develop
any significant decision-making authority at and quantify legally robust risk-based norms
any level should have—and if questioned be and codes of behavior that may be used on a
able to articulate—a good grasp of the firm’s consistent and transparent basis for rewarding and
overall approach to risk and how this links to penalizing staff may also be significant indicators
their operations and policy constraints and the of culture in some instances.
limits that apply to them. Even if individual 132. Even the strongest culture has to be supported
business units do not have formal risk appetite by effective systems and controls. In the early
frameworks, business unit heads should be able to stages of introducing a risk appetite framework,
explain, and respond to challenges on, how their it may sometimes be hard to get individuals at
local strategies and business plans—and the risk all relevant levels to see or buy in to the benefits
implications of these—fit with the enterprise-wide of these. Even where an effective RAF is well
risk appetite framework. embedded, it requires the support of effective
130. The effectiveness or otherwise of the risk appetite systems, controls, and limits. Where appropriate,
framework will also be apparent from the nature supervisors may wish to investigate the degree to
and quality of the dialogue that takes place which such systems support or substitute for an
throughout the organization. Risk and risk effective culture by seeking examples of how this
appetite considerations should be embedded fully works in practice and determining whether the
into decisions about strategy and resources, and relationship is changing over time.
this should be the outcome of discussions based 133. A common problem with all risk appetite
on a shared understanding of risk posture and frameworks is that some key risks are inherently
concepts rather than being constrained narrowly unquantifiable, which in turn, leads to problems
by limits. If questioned, individuals throughout of aggregation. In evaluating the effectiveness of
the business should be able to point to multiple a risk appetite framework, supervisors may wish
instances of such dialogue. It should be apparent to assess a) the extent to which risks that are not
from such discussions that risk issues are part of easily quantified can nevertheless be identified
every day discourse throughout the firm and not and assessed; b) how such risks are assessed
something that are either “added on” or seen as within the context of the risk appetite framework,
someone else’s responsibility. perhaps involving committee structures or other
131. As extensively discussed in this report, a fully means of subjecting them to formal scrutiny; and
effective risk appetite framework is integrally c) the means used to arrive at an aggregation of
bound up with a firm’s culture. The stronger the risks, for risk appetite purposes.
risk culture in a firm, the more secure individuals 134. Stress and scenario testing plays a critical role
will feel in knowing what is expected of them in any effective risk appetite framework. Boards
and the less reliance that will need to be placed and management need to assess the implications
on constraints and coercion. Experience has of severe but plausible scenarios for risk and risk
shown that it can be exceptionally difficult for appetite. Aside from periods of acute system-wide
Boards and supervisors to detect weaknesses in stress, there is no consensus in the Industry that
risk culture in an otherwise performing firm; standardized stress tests designed or conducted
in particular, the absence of obvious contra- by the authorities are beneficial. In a more
indicators cannot be taken as positive evidence normal risk management context, the conduct
and strategic response to stress tests are matters
for management, with supervisors having a key
role in pressing Boards and management to fully
face up to their responsibilities to ensure a) that
the stresses and scenarios are carefully chosen
to balance severity and realism; b) that the tests
are rigorously conducted, with the full range of
implications for the business considered; and c)
that the findings are understood and acted upon.
This last consideration is at least as important as 43
the others; supervisors are encouraged to engage
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institute of international finance
Boards and management (as appropriate) in a
dialogue regarding what the stress tests showed
and what the strategic response was. If the decision
was to make no adjustments to business strategy,
risk or risk appetite, the Board and management
should be able to account fully for this.
annex I: case studies
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RBC’s Risk Appetite Framework is composed of four
The largest circle represents the regulatory constraints RBC faces. RBC’s regulatory
constraints are classified as:
1) Financial – Tend to be quantitative in nature and therefore easier to interpret.
Regulatory
Constraints Capital ratios and liquidity metrics are examples of financial regulatory
constraints.
2) Other – Tend to be predominately qualitative in nature and therefore require
judgment in interpreting requirements and assessing compliance. Examples
include maintaining compliance with legislative and regulatory requirements,
Financial
and adhering to privacy and information security regulations.
Financial
The center circle refers to our risk limits and tolerances that we translate from
risk appetite:
1) Risk limits are quantifiable levels of maximum exposure RBC will accept. They
Risk &
are established only for risks that are financial and measurable, such as
Tolerances credit risk and market risk.
2) Risk tolerances are qualitative statements about RBC’s willingness to accept
risks that are not necessarily quantifiable and for those risks where RBC does
Regulatory Reputational
not have direct control over the risk we accept (such as legal risk and
reputational risk).
We communicate risk limits and tolerances through policies, operating procedures and
Financial
limit structures.
Risk
Profile The striped oval represents the organization’s risk profile at a given point in time.
Regulatory
Reputational
A key element of RBC’s Risk Appetite Framework is Group Risk Management will continue to facilitate and
self-imposed constraints and drivers in which we have oversee enhancements to business segment risk appetite
chosen to limit or otherwise influence the amount of and related reporting.
risk undertaken. We have seven key categories of self-
imposed constraints: Reporting
• Maintain a “AA” rating or better Risk profile relative to risk appetite is reported
• Ensure capital adequacy by maintaining capital quarterly to senior management and the Board of
ratios in excess of rating agency and regulatory Directors. An Annual Enterprise Risk Presentation
46 thresholds is also made to the full Board of Directors. We have
found that a comprehensive and balanced set of our
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framework. While there are distinct linkages to the and risk appetite. In addition, our annual process
Overview—where we are on the journey below we are currently up to the 3rd generation RAS.
Our current capability owes much to the learnings,
The setting of risk appetite within National Australia
insights and persistence of those tasked with earlier
Bank currently manifests itself in two key ways. Firstly,
48 the framework by which we determine our risk posture
efforts.
is strongly aligned to, and informs, the planning We have been preparing RASs for a number of years
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Implementing Robust Risk Appetite Frameworks to Strengthen Financial Institutions
process. Secondly, the statement of risk appetite (the and well before it was becoming an explicit regulatory
Risk Appetite Statement (RAS)) and its three elements expectation. The RAS was created under the leadership
(“posture,” “budget” and “settings,” described below) of the Board Risk Committee and the sponsorship of
sets out our capacity for taking on risk and the settings the CFO and CRO. Whilst rigorous and well-grounded
associated therewith. in principles of corporate finance, the emphasis was on
quantitative risk and capital metrics and not enough on
Our current capability, in terms of risk appetite,
qualitative discussion or actual risk settings, limits and
reflects an ongoing journey over a number of years and
policies. For this reason the RAS remained a centrally
will continue to evolve as our thinking develops. As
managed document with little visibility or traction
with most large organisations, the pace of change is a
beyond the Board and Group Executive.
function of the ability of the organisation to absorb that
change. As such, our strategy for improving the risk Our “second-generation” RASs set out to respond to
appetite has been measured, rather than dramatic, so these identified gaps by incorporating clear, explicit and
as to ensure understanding, acceptance and use as we detailed risk settings, limits and triggers. The drawback
progress. This has allowed us to approach the task with of these RASs was that whilst there was a lot of detail
a longer term vision, introduce change progressively, around risk settings, it became inaccessible to readers
reflect on the responses and then refine our thinking. given its complexity. More important, the Board and
the executive felt that the detail made it hard to “see
The risk appetite framework (RAF) is grounded in:
the wood for the trees” and were of the view that links
• strong engagement between key stakeholders, between the RAS and overall business strategy were
including Board and Executive, in setting the unclear.
planning envelope for the business; and
This issue of the lack of strategic relevance for
• an interactive process over the planning period that the RAS was compounded by the absence of a fully
sees agreement on the risk reward tradeoffs that are integrated role for the Risk function itself within
required for the plan. the planning process. Whilst Risk had a clear role in
The framework results in a statement on risk matters such as the validation of forecasts on loan
appetite, the RAS, which encompasses: loss provisioning or expectations about the movement
in asset quality, it had a minimal part in framing the
• a “risk posture” that seeks to qualitatively describe initial risk envelope in which the business strategies
our capacity and willingness to take risk at and financial plans were to fit.
any point considering the internal and external
circumstances and a forward view; Why was this the case? Apart from the well-
accepted view that Finance “ran the planning process,”
• a “risk budget” expressed as an economic capital Risk lacked both a platform to effectively communicate
limit within which the Group must operate; and its views and a framework to meaningfully participate
• “risk settings” that express key operational limits. in the planning process. In particular, Risk was not
Through a combination of a framework strongly successful in identifying a language that readily
integrated into the plan, and the production of a RAS as conveyed its position and views. Unlike Finance,
the embodiment of risk appetite, we seek to effectively whose language is encapsulated in metrics that are
communicate this appetite throughout the organisation. well understood, the language of risk is somewhat
opaque and not broadly identified with by those tasked
to develop and execute strategy and plan—that is, the
Modest beginnings businesses. Finding ways for Risk to communicate and
The development of our RAS and associated framework engage in planning was thus critical to the development
has been, and continues to be, iterative. As described of risk appetite.
On top of all this, responsibility for preparing the internal and external environment. It effectively sought
RAS frequently changed hands between teams in either to provide direction on whether we were prepared to
Risk or Finance, which made it difficult to establish a take more or less risk. By describing this posture, both
long-term vision or change agenda for risk appetite. in language and visual form, we provided an anchor
point from which to develop the Risk engagement with
Our first steps—dedicated resources and the business units about the respective risk appetite.
defining “risk posture” qualitatively After defining this “risk posture,” it became easier
to debate where we should be, or wanted to be, in
By 2009, we found ourselves at a crossroads. Thinking
around risk appetite was relatively basic and the RAS
terms of a risk stance. This debate could be had at both
the Group level and at each business unit recognising
49
was seen by many as having limited relevance or
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differing market positions, strategic capability and
opportunity to further enhance and enrich the As discussed above, the concept of a risk posture
discussion. To this end we are trialling whether the has allowed Risk to more effectively communicate with
description of a risk posture statement for key risks strategy and finance. We have also developed the concept
(e.g., credit, operational, market, reputation, etc.) and of “key risk themes” within the RAS, which are the
for major business activities would enhance messaging. most important risks (or “categories” of risk) facing the
A direct benefit in developing this thinking is that it Group at any time. They complement thinking around
forces broader engagement with all stakeholders and Group strategies, form a basis for identifying the most
raises awareness around risk appetite. relevant points of vulnerability in the plan and provide a
framework for thinking about risk mitigation. In addition,
because they are described in common language rather
Along the path—completing the picture than technical terms, they provide a more broadly
Whilst describing a risk posture was a catalyst for understood link for those outside the Risk community.
increased debate at Executive and Board level, and
Having established the role of “risk posture” (a
one that has seen the quality of discussion around
qualitative risk setting description) in risk appetite we
risk appetite increase throughout the Group, other
have also sought to enhance our thinking around the
developments have also been important.
more quantitative aspects of the RAS, in particular:
A key development has been increased engagement
• setting a “risk budget” in terms of economic
by Risk with the Strategy and Finance teams in
capital; and
the development of the strategic, financial and risk
parameters established for the planning process. • describing operational “risk settings” to further
This has allowed us to more effectively integrate risk enhance the communication with bankers.
appetite into the planning process, as businesses see the The “risk budget” is described in economic capital
three key Group functional stakeholders (in risk, finance terms and sets our maximum risk taking capacity.
and strategy) more closely aligned and linked in their Reflecting the posture, it establishes a limit in advance
messaging around the drivers of financial outcomes. on the use of our available risk capital to support
From a Board perspective, increased engagement business activity. Allocated to the businesses by risk
between the Group functions has provided comfort that class (e.g., credit, market, operational
risk, etc.), it provides a quantitative
Exhibit 1: Risk appetite in the planning cycle boundary for planned activity. Actual
use of economic capital is then measured
Risk Appetite
• Economic capital
against these limits. This approach has
• Posture served as a trigger to review increased
• Limits
• Scenarios & stress tests
The
business activity in certain areas where
• Trade -offs
development of
RiskRisk
Appetite, Financial Plan
economic capital limits were likely to
Appetite,
andFinancial
StrategyPlan
are integrally be insufficient to support the proposed
connected
and Strategy is
Strategy Group Financial
iterative activity.
plan All three communicate risk /
• Target markets / planning • P&L reward ‘trade-offs’ to be In the past, economic capital would
segment • Balance sheet made, though with different
• Action plans
• Trade -offs
• Capital & funding language not have acted as such a constraint as it
• Trade -offs
had always been an outcome of the plans
(i.e., the agreed upon plan used “this”
amount of economic capital) and as such
was not seen as a limit on activity or as a
trigger point for a decision.
Having set a “risk posture” (qualitative) and a Lessons learned—successes and challenges
“risk budget” (quantitative), we then establish “risk along the way
settings” to further provide guidance as to the risk
tolerances within which the Group should operate. The developments described above have been
These risk settings are represented by limits, policies interactive with enhancements to both the RAS and the
and procedures and other setting statements and are framework occurring as we progressed. In the course of
more operational in nature. They are at different levels our journey, the absence of an “off the shelf” solution
of granularity depending on the messaging required. has meant we have spent significant time discussing
what works and what doesn’t. Our approach has always
This approach to the RAF is shown below. been to demonstrate ongoing steady improvement 51
Whilst the framework for the RAS and risk appetite rather than coming up with the “complete solution.”
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institute of international finance
was evolving, we were conscious that communication Given the uniqueness of the issue, the multifaceted
through to bankers remained a challenge. The language nature of the challenge and the relative interest and
of the RAS is targeted at the Board, Executive and needs of stakeholders, we have concluded that this
Senior Management. Beyond this, the language is less is not achievable. Rather, ongoing development and
appropriate for day-to-day activity. Notwithstanding, it refinement will lead to better outcomes.
is clear that effective communication to bankers needs Against this backdrop, there are lessons we have
to occur in some form if the RAS is to fulfil its role of learnt along the way that have shaped, and continue to
“Board to Banker” understanding of risk appetite. shape, our thinking.
To this end we have sought to engage businesses The things that have led to significant improvement
in preparing their own “risk-setting statements” for us include:
(RSSs) that can be more granular and effective in
communicating messages to all levels of the business. • fostering leadership of the debate on risk appetite
Whilst these clearly need to align to the RAS, they from the CEO, the CRO and the Board Risk
provide more latitude to effectively communicate to a Committee;
broader audience. Although some progress has been • fostering a receptive internal environment. The
made, this remains a work in progress. organisation has worked hard on its culture over
time and has a strong emphasis on teamwork,
Exhibit 2: From risk posture to risk budget and actual risk settings
Risk settings
Existing Customer Controls
Outlook franchise needs
• Models • Hurdles
• Trading (e.g. x-sell,
limits return, LVR,
etc.)
Potential • Op. loss
• Policies
rewards tolerance
• Audits
Limits
Confidence in Risk Risk • Industry • Equity
capabilities posture budget • Country • Product
• Market • Liquidity
• IRRBB • etc.
Expectations
for return
Processes / procedures
• Making • Customer
decisions onboarding
• Product • Training
exposure
Regulatory Legacy monitoring
Risk-taking
capacity constraints assets /
liabilities Messaging
Not all risk settings are in the RAS–but all are consistent with it
collaboration and enterprise thinking. This, and generality that qualitative, “principles-
alongside the wake-up call issued to all parties based” definitions provide. We have responded by
associated with the financial services sector (arising developing a number of quantitative metrics which
from the global financial crisis and its aftermath), are “indicative” of risk posture whilst avoiding the
has enabled more sophisticated and planned trap of attempting to define it formulaically.
discussions and analysis on the forward outlook for • choosing the appropriate metric for each
risk and the environment and our response through application. For example, economic capital is the
posture, appetite and strategy; metric for risk “budgeting” across the Group, but
52 • identifying a single, dedicated team with
accountability for the RAS and the broader
other metrics are more useful for other applications,
such as exposure limits, trading desk limits,
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framework has allowed us to attain consistency in industry or country credit exposure limits, etc. Our
Implementing Robust Risk Appetite Frameworks to Strengthen Financial Institutions
approach and provide the impetus for innovation; response has been not to promote a single all-
• separating discussion of risk appetite into three encompassing risk metric but rather to identify the
parts, each of which are linked but serve a different most appropriate risk metrics for each purpose.
purpose: risk posture, risk budget and risk settings; • whilst used as the measure of risk budget, the use
• integrating the risk appetite and RAS with the of economic capital still remains a challenge. We
strategic and financial planning process; continue to use it given its historic link to past
RASs, ICAAP and the fact that most measured risks
• increasing the dialogue with the business units can be quantified in economic capital terms (albeit
around their view of risk posture; there is always debate as to the voracity of the
• delivering three RASs to the Board with the cycle number). Notwithstanding this, most stakeholders
and content linked to the planning process. This still have little engagement with economic capital
has allowed for more regular Board discussion on as a meaningful metric to measure risk performance
risk appetite and has reinforced the link between against. The proper place and purpose of economic
risk appetite and the business strategies and plans. capital as a useful tool in the RAF continues to be a
The Board now sees more careful consideration of focus.
the implications of proposed actions and activities • never allowing the sole use of “risk adjusted”
on the Group risk profile and its relation to the metrics (like economic capital, RWAs and VaR) to
Group Risk Appetite and evidence of risk appetite lead us to lose sight of the underlying nominal
thinking in its discussions with management; exposure behind each risk. Banks lose dollars, not
• supplementing the RAS and associated discussion economic capital—and the same can be said of
with risk workshops and targeted risk papers shareholder dividend payments—so we always seek
for the Board, has assisted the Board in linking to ensure visibility of unadjusted exposures when
risk appetite to the business activities and the discussing any risk.
portfolios; • integrating meaningful stress testing into the risk
• engaging with our Regulator; appetite and planning framework, including setting
limits more systematically and drawing insights
• identifying key stakeholders in the business to
from the results, which is a task that is still a work
champion risk appetite discussion; and
in progress; and
• maintaining the ongoing commitment of key
• balancing coverage of credit risk (our largest
stakeholders such as the Board and senior
single risk type), with other material risks (such as
executive.
operational or reputation risk), which are less easily
Most important, we can already say that in the past quantified or described. As with stress testing, this
few years the outcome of a number of material strategic is still a work in progress.
decisions taken by the Group were significantly
influenced by the framework described above.
Where we go from here—further increasing the
As there are diverse views around the approach to value of the Risk Appetite Framework
risk appetite (and the RAS) our journey has not been
without challenges. Some of the more significant The journey never ends. Whilst we have made progress,
challenges have been: we are of the view that further enhancements can
be, and will be, made to our RAF to increase its
• balancing the desire for quantitative or prescriptive effectiveness within the Group. In recent discussions
criteria to define risk posture with the flexibility with stakeholders, including Board members, a range of
issues have been identified that would further enhance • aligning Risk with Strategy and Finance;
the impact of the RAS and associated framework • fully engaging Risk as key participant in the
including: planning process;
• further progressing the discussion around stress • continuing to develop thinking around the RAF by
testing, scenarios and responses and incorporating engaging with the key stakeholders; and
this more robustly into the planning process;
• seeking ways to broaden the view and
• continuing to complement the use of economic understanding of risk appetite so others feel more
capital with consideration of other key measures engaged in its development.
such as regulatory capital and simple, unadjusted
The benefits from the advancement of our RAF
53
exposure;
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and the alignment on issues of strategy, finance and
The year 2008 marked a strategic inflection point large extent, siloed by risk type. The inter-connectedness
for the world’s view on “risk.” The financial crisis of risks was only beginning to be aggregated. And
compelled the Risk Management discipline in global various dimensions of financial performance and
54 financial institutions to re-assess every method and
assumption embedded in their processes. Three years
strength were not consistently being viewed through a
risk lens. Risk managers across the industry began giving
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later, we can all reflect on how financial institutions more consideration to defining risk appetite as a guide
Implementing Robust Risk Appetite Frameworks to Strengthen Financial Institutions
have evolved their risk frameworks, including, for decision-making—to frame how much risk their firms
to various degrees, a deliberate, robust and clear were willing to take on in the context of executing their
expression of “risk appetite.” business strategies and in the drive for value.
This case study captures the challenges and lessons At the time, Scotiabank participated in a Canadian
in the design and implementation of a Risk Appetite benchmarking survey, conducted by Deloitte, as one
Framework at Scotiabank (the Bank). Today Scotiabank input to defining appropriate practices. The study
considers implementation of their Risk Appetite confirmed that risk appetite was an active area of
Framework to have been successful. For perspective, focus for the banks and that formalization would take
however, Scotiabank was not starting at the beginning. the form of a Board-approved framework with ties to
It already had a risk appetite position embedded in its capital management and other management activities.
strong risk culture that had served it well through the There is general industry consensus on the meaning
financial crisis. Nonetheless, Scotiabank recognized the of “risk appetite” and the importance of distinguishing
potential value of a more clearly defined, comprehensive it from risk capacity. The broadly held view is that
Risk Appetite Framework based on governing financial risk appetite is an expression of the desire to take
objectives, risk principles and risk appetite measures. risk and, implicitly, a statement of how returns will be
Scotiabank integrated these key dimensions into an earned against that risk. It is, in effect, a key part of the
enterprise-wide framework, strengthening its overall contract between senior management and the Board …
approach to governing risk-taking activities. The Risk and the shareholders they represent. Risk appetite is
Appetite Framework was approved by the Bank’s Board clearly distinct from risk capacity, which is the ability
of Directors in early 2010. The journey of evolving that of the firm to withstand risk events. However, that
Framework continues. seems to be where the industry consensus ends. To date
there is no common approach beyond definitions and
Enterprise Risk key elements of a framework at the corporate level.
In 2006 the Bank created an Enterprise Risk function
with a mandate of linking capital capacity, revenue Setting Context
and risk-taking across the various risk types (e.g., The Bank’s most senior executives were actively
credit, market, liquidity, operational risk, etc.). The engaged in industry discussions relating to risk,
first priority of the new team was the development of implications of the global crisis and the subsequent
appropriate and actionable risk metrics. From there, a way forward for the industry. Senior executives became
comprehensive information package was developed for involved in IIF benchmarking efforts, supported by a
regular reporting to senior management and the Board broad cross-section of management.
on all risks spanning the entire Bank against key Board-
approved risk limits, globally, creating a clear picture of The Enterprise Risk mandate was expanding in
the Bank’s risk exposures. Additional priorities included several ways. In addition to becoming central support
further development of the Bank’s credit risk strategy. for the IIF benchmarking analysis, the team began
With these developments, the Board was more informed integrating risk measures from across the firm. They
and could become more engaged. Together, these risk started to serve as a clearinghouse for all types of risk
limits, and various risk reporting aspects, helped senior information, and as a risk communications channel
management articulate to the Board the amount of risk for senior management and the Board. Without a more
being taken at the institution. defined Risk Appetite Framework, however, the risk
reporting lacked context. So the team conducted an
By 2008 it was evident that a broader strategy was internal assessment of what was in place and confirmed
required. Risk Management at the Bank was still, to a the following:
• The Bank already had an implicit risk appetite Diving In
embedded in its strong risk management culture. At
The first iteration of the Risk Appetite Framework
Scotiabank, the risk culture is anchored in a long
involved selection of existing quantitative metrics
history of who we are as a lender, from our early
(covering Board-approved risk limits, performance
days of financing North American Eastern Seaboard
targets and capital targets) as key indicators of the
trade to the launch of our first personal loans in
Bank’s risk appetite and actual risk profile. The
1958, and continuing today with market leading
indicators were consolidated and incorporated into
financing programs around the world. Our deep
the Capital Management Policy. By the end of 2008,
experience in lending has embedded a focus on
capital preservation that spans the full spectrum of
however, it was evident that a more complete policy 55
was needed.
risk … making risk management a strategic priority
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institute of international finance
shared by all employees. Today, a key aspect of Development of the next iteration of the Framework
this culture is to be well-diversified across business focused on a few key areas:
lines, countries, products and industries. Another • The context of the Bank’s governing financial
key element of the culture is the relatively long objectives and strategic principles;
tenure of employees. For example, of Canadian-
based managers—people in decision-making • Articulation of Risk Management principles
roles—over one-third have been with the Bank more (qualitative attributes) that would guide the Bank’s
than 20 years. And the Executive Management overall approach in risk-based activities;
Committee’s tenure is even longer. Based on that • Bringing into focus a limited number of risk
deep experience, senior management has a strong measures that were considered essential objective
sense for what would be “offside” relative to the expressions of the Bank’s risk profile, along with
cultural norms established over almost one hundred corresponding target ranges; and
and eighty years; • Establishment of monitoring and reporting
• Existing limit structures were, in effect, a network structures.
of contracts already in place between Risk Development of the Risk Appetite Framework was
Management, the Business Lines and the Board on driven by Risk Management in collaboration with a
what risks could be taken, or not; and broad range of stakeholders. Finance was a pivotal
• Business lines clearly owned risk, complemented partner in the work as they had overall management of
by highly centralized decision-making on risk the Bank’s Balanced Scorecard (more recently moved to
policy setting and significant transactions through the Strategic Planning Office). As well, Global Human
executive committees. Resources ensured that employee incentives are linked
However, to performance, and that risk performance is taken
into consideration. Engagement of senior management
• The existing limit structure was complex and not in the Business Lines was a key part of the review
codified in any way that made it straightforward to and approval process. The Bank’s Asset & Liability
combine and report the total risk taking activities Committee served as the forum for review prior to
to the Board; and presentation to the Executive Management Committee,
• There was no explicit statement of the objectives and ultimately the Board.
and principles that governed the Bank’s decisions The approach could be relatively expedient based on
for risk-taking. a few factors:
Most experts on “risk appetite” acknowledge that • The well-established risk culture;
the development of a framework should engage senior
management in the Risk Management function and in the • The independence of the Risk Management
Business Lines, as well as the Board. However, the biggest oversight function; and
obstacle to developing the framework and implementing • The specific limits to be brought into the
it can be the lack of consensus on what risks are Framework could be largely to be drawn from the
appropriate for the firm and the extent of controls network of existing controls.
needed to mitigate the risks. So, when there is broad The Framework that emerged from the discussions
appreciation of an established risk culture along with had two sides: a qualitative, principles-based
specific risk-based contracts already in place between the component, and specific risk measures in key risk
stakeholders, the task of designing and implementing a disciplines. More specifically, the structure was
risk appetite framework is already well advanced. underpinned by sound risk governance, followed by
the Risk Appetite Framework itself. The use of risk In discussing Scotiabank’s overarching Risk
management techniques was considered to be another Management Framework, the Bank is now more able
key component, including the strategies, policies, limits, to enunciate the relationship of risk governance,
processes, measurement and monitoring tools which risk appetite and risk management techniques and
Risk Management implements. These risk management the foundation of these in the Bank’s strong risk
techniques are deployed across the spectrum of risk management culture.
disciplines covering credit, market, liquidity, operational
and reputational risk. Finally, the entire structure is 2010 Annual Report
underpinned by the Bank’s strong risk culture.
56 The Report notes that the Risk Appetite Framework
consists of four components and elaborates on each:
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institute of international finance
strong and functioning Risk Appetite Framework can
sustainable earnings growth, maintenance of be accomplished in the setting of a strong, existing risk
adequate capital in relation to the Bank’s risk culture where there is a deep network of established
profile and availability of financial resources to controls, limits and risk oversight structure. The
meet financial obligations on a timely basis at development of the Framework was the straightforward
reasonable prices. part. Work continues on key challenges around
4. Risk Appetite Measures provide objective metrics implementation and further alignment.
that gauge risk and articulate the Bank’s risk The key challenge continues to be a combination of
appetite. They provide a link between actual 1) awareness and application of the Framework within
risk-taking activities and the risk management the Business Lines, and 2) finding the right balance
principles, strategic principles and governing between broad principles and granular guidance for
financial objectives. These measures include day-to-day decision-making with line management
capital and earnings ratios, market and liquidity throughout the Bank.
risk limits and credit and operational risk targets. In terms of awareness, the program was launched
with “road shows,” but more communication work
needs to be done to evolve from reliance on the culture
Strategies, Policies Guidelines, Processes and norms, to embedding the Framework as the more
& Limits & Standards clearly defined and rigorous context for decision-
making.
As for “the right balance,” there still needs to be
Risk Management linkage between the high-level principles and metrics
Techniques as expressions of risk appetite at the top of the Bank
and the risk indicators and limits deployed at a
business unit level. While some measures of credit and
Measurement,
market risk have been allocated to businesses, others,
Monitoring
& Reporting including most measures for operational risk are not
easily aggregated, nor divided. As such, the Bank (and
the industry) continues to work at an effective way to
• Risk management techniques are regularly reviewed and
link certain “top of the house” measures with business
updated to ensure consistency with risk-taking activities, and
relevance to the business and financial strategies of the Bank specific risk performance measures.
Additional work also remains to further integrate the
Risk Appetite Framework with other risk policies and
Key Benefits, Challenges and Future the enterprise-wide stress testing program.
Considerations Ultimately, Scotiabank’s test of an effective Risk
Appetite Framework is that it fits the organization;
The Framework is envisioned as a living document
the Board understands it; management is having good
that will undergo periodic review and update. The
discussions reflecting both qualitative and quantitative
Bank considers it to be an evolving guideline that will
measures; decisions are made and action is taken; and
continue to be disseminated internally and which will
sustainable long-term earnings growth is achieved.
Risk appetite framework development at the Commonwealth
Bank of Australia
Dimension 4 Dimension 3
If the role of risk management is thought of in terms © CBA Group
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Armed with this base input we were able to translate need to link it to the remuneration system and this has
This responsibility was an important part of the cultural leading to keeping RASs fresh and appropriate.
change, with the business themselves rather than Risk
Management being responsible for the risks being taken Figure 3: The critical link between appetite
on and for their outcomes.
and strategy
Board members read these documents to test their
specificity to the activities of the business unit, and also Bedding RAS in...
as a lens through which to view the strategies presented Links it to other critical elements in a risk framework
by businesses. CBA Group Vision and Values
Bedding in RAS BU RA
r e qu i r e s c a s c a di n g BU
BU1
BU2 Business Unit (BU) challenges
RA
Strategic Risk Appetite Group
BU3
Principles Supporting limits BU4
Plans Statement/Policies
Validate or challenge
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institute of international finance
consideration and refinement of strategy and risk businesses.
appetite is now part of business as usual. (See the • Further development is ongoing in adding clarity
“Assess & Revise” arrows in Figure 3.) to business unit RASs and strategies so that they
• By establishing clear boundaries, Business units become more overtly complementary and aligned.
understand what is outside appetite and therefore • The incorporation of stress testing outcomes into
do not pursue these opportunities, leading to a the contextual setting of risk appetite is an area
reduction in both wasted effort and frustration. that we continue to develop.
• By bringing the requirement to operate into
alignment with the Group and local risk appetite Summary of key lessons learned
statements into the performance management and
remuneration framework, risk appetite has achieved As the risk appetite has been developed a number
a high level of awareness and influence on of lessons have been learned, the foremost of which
behaviours. Key behaviours are found in the Group include:
RAS, e.g., responsibility to raise issues, protection • Without sponsorship from the top it is difficult
for doing so and “no harm” to people who raise to get traction in developing a risk appetite
false-positive issues. framework.
• Without a clear conceptual definition of risk
Continuation in the evolution of risk appetite appetite there are many confusing and ineffective
Although considerable success has been achieved in the discussions about risk management and we fail to
risk appetite journey so far, we are cognisant that there get business buy-in to the framework.
is more to be done in developing the maturity of risk • The conversations around risk appetite are equally
appetite across the Group. as important and beneficial as the actual Risk
• By necessity, the Group RAS is high level and Appetite Statement document produced from them.
principle based in nature. The challenge is in • Culture is a fundamental part of risk appetite and
cascading this to lower levels in a way that makes to the success of embedding risk appetite in the
it meaningful in day-to-day decision making on organisation. Taking the time to craft descriptions
the front line. Business units are developing risk of what risk appetite the Group and business units
parameters for lower level portfolios/products that have for variance in risk culture breathes life into
will translate the limits/principles established in risk culture.
the Group and business unit RASs into meaningful
limits for staff working in these areas. This
will allow a more granular inclusion of RAS
consideration into performance assessments and
incentive payment outcomes.
Annex II: Summary of the responses to
the Survey
1
Alpha Bank, ANZ Banking Group, Barclays, BBVA, BMO, BNP Paribas, Bank of America, Bank of Ireland, Commonwealth Bank [of Australia],
Commerzbank, Credit Suisse, Danske Bank, DBS Group, Deutsche Bank, Erste Bank, FirstRand, Handelsbanken, HSBC, ING, Itau, Macquarie, Mercantil,
Mizuho, Mitsubishi UFJ Financial Group, National Australia Bank, Nordea, Norinchukin Bank, RBC, RBS, Santander, Scotiabank , SEB, Société Générale,
State Street, SunCorp, SwissRe, UBS, UniCredit, WellsFargo, and Westpac.
Chart 1: Respondent Firms Chart 2: Respondent Role
Market Capitalization Activities undertaken
3
4
30% 23%
HQ Location
EMEA
Number of firms
22
5
63
13 6 10
6 7 4 76% 87% 89% 50%
|
Asia & Oceania 10 $0 – $25 – $50 – $75 – $100 bn
32 Investment Commercial/ Retail/ Insurance
Multiple countries within single continent Multi-continent Chief Risk Officer Member of the Risk Committee of the Board
14 11 8
Global (Presence on all 5 continents) Member of the Management Board 7 CRO direct report
11 8 7 6 8
Other
$0 – $500 – $1000 – $2000 bnMember of the Board25of–Directors
0 – 25k 50 – 75 – 150k +
$500 bn $1000
Business bn $2000 bn
area leader + President and/or CEO50k 75k 150k
mber of firms
22
13 6 10 7 4 76% 87% 89% 50%
14 11 8 7 11 8 7 6 8
20
15
10
5
1
2 4 23 7
0
Not embarked Little Some Good Successful
on the process Progress Progress Progress implementation
risk appetite framework (Chart 3). This has required bilateral discussions and other forums suggests
a careful processing of the responses, which has that, in general, progress in risk appetite across the
been done with support from Ernst & Young and Industry and in a number of specific jurisdictions
PwC, in order to provide a solid foundation for the substantially lags the progress reported by the
further work and analysis from the IIF Working group of survey respondents.
Group on Risk Appetite and for this report. A significant minority is confident about what has
• The questionnaire was completed by senior been achieved: more than 15 percent of the respondent
executives in the firm, and in many cases feedback firms consider that all of the major challenges have
64 from multiple executives was provided. Not
surprisingly, a significant share of the responses
been overcome and that the implementation of the RAF
has been a success. These firms are essentially where
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(more than 40%) was provided by CROs. However, they want to be on risk appetite and feel they have also
Implementing Robust Risk Appetite Frameworks to Strengthen Financial Institutions
the participation of Board members was significant achieved many benefits. In particular, the successful
(Chart 2). implementation process and the debate around the RAF
has taken the risk discussion to a much more strategic
I. Assessment of the Experience level and has resulted in business management at every
level having a more robust discussion around the risks
to Date in Implementing a Risk and the appetite for stress and adverse conditions,
Appetite Framework rather than only focusing on performance measures.
Four firms have responded that they have made some
Overall Assessment of Experience in progress, while only three survey respondents have made
Implementing a Risk Appetite Framework little progress or have not embarked on the process.
• When assessing the overall experience to date, • Participating firms also recognize that, even when
a large majority (almost two thirds) of the firms good progress has been achieved, much work is
participating in the survey stated that they are still needed. Chart 5 shows firms’ key priorities and
making good progress in implementing an RAF, objectives in their next steps on the implementation
according to their own self-assessment; at the same journey. These results are consistent with the key
time, they also recognize that a comprehensive and challenges highlighted by firms and presented in
successful implementation of the RAF will require the next section. Consistent with what emerged
moving the approach deeper into the business, in terms of the key challenges highlighted by
work that these firms consider as still underway. firms and presented in the next section, the key
Similarly, in a number of cases, these firms next steps most frequently mentioned by firms as
highlight that, despite the good progress achieved, their next priority in the implementation journey
their RAF needs to reflect a more deeply embedded were: continue embedding the RAF within the
culture of risk within the wider business and to business and cascade it to all levels, functions,
develop a deeper link with the strategy and the lines of business, and risk categories; build a robust
planning activities (Chart 4). measurement and monitoring mechanism; and
achieve a stronger integration between the RAF and
• At this point, it must be emphasized that while
strategic planning.
good progress in general is being self-reported
by the respondents as a
group overall, this group Chart 5: Key Priorities and Objectives
most likely represents 0 2 4 6 8 10 12 14 16 18
some of the more
Integrate risk appetite into ongoing management 16
advanced practitioners of the business
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exposure across activities and portfolios.
challenges involved in such a process. The chart Only high level quantitative outcomes 9
• Managing the business to a target credit rating • Target Tier 1 and core Tier 1 ratio levels
or better • Economic capital per risk type
• Ensuring capital adequacy • Return on equity
66 • Maintaining low exposure to “stress events” • Earnings per share growth
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• Earnings volatility
• Meeting regulatory requirements and • Stress tests
expectations
• RWA limits
• Ensuring sound management of liquidity and
funding risk • Liquidity ratios
• Requiring assessment for fit to risk appetite for • Limitations of client exposure
significant projects, new products, and entry • Industry concentration
into new markets
• Country envelopes
• Creating statements concerning
• Rate of return required from our businesses
nonquantifiable risks (e.g., reputational risk)
• Value at Risk for trading portfolios
• Creating statements of general market
sentiment, of the overall macro environment, • Loan loss ceilings for loan portfolios
and of broad areas for business growth • Assets-to-Capital Multiple
• Maintaining minimum dividend payout levels • Operating leverage
under severe but plausible stress levels
• Maintaining sustainable economic profit
A wide range of detailed quantitative measures,
commensurate with the risks taken
often at the business level, are also included in the
• Maintaining a well-diversified funding statements:
structure
• Keeping off the balance sheet those vehicles
• Maximum total exposure to indicate to market
nonmaterial in size relative to the size of the
valuation fluctuations in the trading book as
balance sheet
measured by a maximum Value at Risk over a
• Harnessing benefits from business certain time horizon
diversification to generate nonvolatile and
• Maximum economic value risk from market
sustainable earnings
value movements stemming from interest rate
• Using robust and appropriate scenario stress and FX mismatches in the banking book as
testing to assess the potential impact on the measured by delta 1% and aggregated nominal
group’s capital adequacy and strategic plans FX mismatch
• Avoiding significant losses from small and • Minimum quality standard for large single
more-peripheral businesses that are not central name exposures as measured by average
to the key strategies (non-core risks) internal risk grade of the top 20 counterparty
• Restricting business to activities that are groups, banks, and corporates separated
understood and that can be adequately priced • Credit portfolio quality statements;
(e.g., without “look-through” analysis) quantitative statements on credit risk,
including loan losses and concentrations;
• High-level quantitative outcomes. Qualitative market risk, including use of capital and
statements are normally combined with a maximum losses
reasonable number of quantitative metrics in order • Clear guidelines regarding maturities and size
to be able to monitor and take adequate actions of trades
discussions with Working Group members revealed
• Hurdle rates for performance measures (RoE, that the regular, daily dialogue that occurs in risk
RoRAC) committees and with risk staff, including those
• Quantitative measures applied to involved in credit approvals, play an important role
nonquantifiable risks (e.g., data from customer in communicating risk appetite concepts to front-
polls, investors polls, employee sentiments, line staff and making these concepts “real” on a
media coverage, interactions with regulators) day-to-day basis.
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0 5 10 15 20 25
0 10 20 30 40 50 60
Implementing Robust Risk Appetite Frameworks to Strengthen Financial Institutions
appetite.
Capital Capacity 50
Budget Targets 28
• As to the optimum number of parameters
Liquidity or other 26 that strikes the right balance between being
market constraints
comprehensive and comprehensible, a wide range
Culture 16
of answers has been gathered; however, typically
Shareholder input 16
and perspectives no more than 10 measures are considered at the
Stress Test Results 16 Board level with increasing detail to support at
External market 10
dynamics/considerations
business and operational levels.
• In the large majority of cases, such measures tend
to focus mainly on the enterprise level only and
• The risk appetite process is seen by firms as reflect Board-level approved limits and objectives.
dynamic, where risk taking can be re-aligned on However, it is quite common to see also a number
an ongoing basis. In the vast majority of cases, of more specific (e.g., business-level) metrics that
this is achieved through an ongoing monitoring— operate at division or business unit level.
including Board reporting—of risk appetite elements
• Stress testing and stress metrics play a role in the
(e.g., performance against risk metrics) and
risk appetite framework of almost all respondents
adjustment as needed.
(only one firm stated that they are not used). The
use of stress testing varies: some banks are putting
Risk Appetite Metrics stress tests at the center of the appetite setting
• The survey explored the metrics that have an process, whereas others are using stress tests to
important role to play in establishing and operating “sense-check” or challenge their risk appetite
an effective risk appetite framework, namely those settings. Chart 12 summarizes the role that stress
metrics that are routinely used in interactions testing and stress metrics play in the risk appetite
between the Board and the management when framework.
20
15
10
0
ROE
Earnings Volatility
EPS
Growth measures
Capital Ratios
Stress Testing
EC
RWA
RAROC
VaR
Concentration limits
Limits
Cost of risk
Internal ratings
EL
Provisions
Specifying risk appetite only Monitoring compliance only Both specifying and monitoring
The risk appetite is set at the enterprise level
Chart 12: Role of Stress Testing and and cascaded down into the lines of business
Stressed Metrics via specific line-of-business risk appetite
0 2 4 6 8 10 12 14 statements and other key risk indicators set at a
Effect on capital adequacy 12 more granular level that ensure that individual
A risk appetite measure 9
portfolio performance is within defined
Results compared against 9
tolerances.
risk appetite
Translating high-level risk appetite metrics into
Used in limit setting 8
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Used in developing 3
key figures are broken down to the business-
Chart 13: Approach on Nonquantifiable Risks When an enterprise-level Risk Appetite metric is
0 1 2 3 4 5 6 7 8 exceeded, the Risk Executive will notify the Chief
Qualitative management 8 Risk Officer and the related Line of Business
assessment/guidelines
Non-quantitative measures 5
Executive. The Global Risk CRO will notify the Chief
are not considered yet Executive Officer, Chief Financial Officer, Chair of
Developed proxy measures 3 ALMRC and Chair of ERC of the limit excess. This
Not considered - covered 3 notification includes a plan of risk reduction.
by policies
Captured under “Business Risk” 2 Additionally, Action Triggers are set to
Some risks cannot be followed 1
alert management when a metric is nearing an
through metrics enterprise-level Risk Appetite limit. When an
Developing KPIs for 1
Reputational Risk Action Trigger is exceeded, the Risk Executive will
Consider Risk to Market 1 be required to acknowledge/approve the excess.
confidence
The Risk Executive will notify the CRO and Head
of that particular LOB of the Trigger breach. The
• There seems to be no uniform process for CRO will notify the Chief Executive Officer and
translating high-level risk appetite indicators into Chief Financial Officer. This notification includes
more specific measures such as risk limits and a plan of action developed by the LOB and Risk
tolerances. However, the following techniques were Management to cure the breach in a timely manner.
often mentioned in the responses: All excesses of both limits and triggers are
The budget and planning process cascade reported on the Summary Risk Report to executive
metrics, such as RoE, net funding needs, and management and the Board.
RWAs, at a more granular level.
The key risk forums in which strategy is • In a few cases, it would be more accurate to
discussed in the light of risk, liquidity, and characterize the process for dealing with limit
capital considerations translate high-level risk breaches as a “comply or explain” one, including
appetite indicators into more specific measures.
procedures for granting exceptions, while Board Risk Committee members, with risk
contingency planning plays a role only in the more issues is fundamental. A large number of
serious cases. A number of firms explicitly link this firms report that the time and frequency
process with their work on recovery and resolution devoted to risk issues has been increased.
planning. • Separate meetings focused on risk: Fluent
Moreover, those firms that do not have a formal communication on risk appetite between the
contingency plan for being outside the risk appetite (an Board and senior management, including
event that should be a very rare occurrence) state that some workshops for Board members, and
70 this would certainly cause a management review and
Board Risk Committee discussion.
creation of a Board-level forum dedicated
to risk with frequent meetings and effective
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strategic issues in the businesses come difficulties mentioned above:
2
The empowerment of the CRO was a key finding and recommendation of the July 2008 report of the IIF Committee on Market Best Practices.
Biggest Achievements,
Chart 14: Implementation Challenges
Benefits, and Key Next Steps 0 2 4 6 8 10 12 14 16
• Respondent firms are at
Establishing effective risk culture 9 5 1
different stages of developing at all levels in the bank
their RAFs, and their business Establishing consistent approach to risk
8 4
models are characterized by across all business/products
the identification and design Clear and agreed framework to integrate risk,
9 2
of a clear, comprehensible, strategy and capital allocation
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institute of international finance
• Natalia Rocha, Staff Assistant, Regulatory Affairs
Implementing Robust Risk Appetite Frameworks to Strengthen Financial Institutions |
74
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