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1、.原文:Effective risk management in financial institutionsAbstract:Risk management is more important in the financial sector than in other parts of the economy. But it is difficult. The basis of banking and similar financial institutions is taking risk in conditions of uncertainty. Describes how the Tu
2、rnbull report, for which the author was project director, created a new underlying approach to risk. Provides a guide to the way in which the various Turnbull ideas have become the bedrock of risk management and suggests how they can be developed.There can be few, if any, parts of the economy in whi
3、ch risk management is more important than the financial sector. Financial institutions account for a sizeable number of the worlds leading companies and have a critical role to play in the economics of every country and thus in world economic order as a whole. Their whole business is centred on taki
4、ng risks in conditions of uncertainty. The Turnbull Report on risk management and internal control, which is applicable to all listed companies in the UK and which has been widely disseminated internationally, fully recognises this fundamental point. Its focus is on effective risk management and not
5、 the elimination of risk. In a modern competitive market economy, business organisations that are risk averse are unlikely to earn satisfactory returns. On the other hand, highly volatile returns are unlikely to find favour with capital markets anxious not to be surprised, particularly by bad news.
6、Moreover, Turnbull is as much about doing the right things and not missing strategic opportunities, as it is about doing things right, essential if a company is to achieve its full potential. Applying Turnbulls approach may lead to some financial institutions realising that they are not taking enoug
7、h risk; perhaps a new market can be identified and while there may be clear risks in being the first to enter there may equally be significant first-mover advantages to be gained.A framework, not a rule bookThe Turnbull Report also recognises the dynamic nature of markets in which an organisation op
8、erates and seeks to encourage companies to create risk management systems that can continually adapt to changing circumstances. To avoid particular controls being seen as an end in themselves even once their usefulness has ceased, the guidance places internal controls firmly in their broader busines
9、s context: they are only of value to the extent that they help businesses to control the risks that threaten the achievement of their business objectives. In summary, Turnbull offers a framework, rather than a rulebook, which each organisation can apply to its own circumstances to develop an appropr
10、iate internal control system.The importance of sound judgementThe fact that Turnbull eschews a tick-box approach has been well received by the business community; however, it does mean that judgement plays a vital role in establishing an effective internal control system, starting at board level. Ma
11、king sure that judgement is sound is perhaps the greatest single challenge involved in risk management. No system and no amount of internal controls will prevent losses if the judgement on which business decisions are based is poor.Judgement comes into play in initially establishing clearly defined
12、business objectives, identifying the risks to achieving those objectives, prioritising how great a threat those risks pose and then determining appropriate responses in the form of developing internal control systems.Judgement is also called for in terms of applying cost-benefit analysis to the meri
13、ts of adopting specific controls. It is clearly worthwhile for a bank to undertake credit checks before granting loans but a cost-benefit approach will promote systems that focus staff time on the potentially high risk loans and on developing early warning systems when loans are not performing rathe
14、r than selecting a one size fits all approach.Identification issuesRisks that threaten a financial institutions objectives will often range from highly function-specific risks through to strategic, big picture issues. Consider the foreign exchange trading activity in a major bank. There is clearly a
15、 risk that an individual trader, left to operate free of internal controls, can run up significant losses. This risk is located in a defined area of the banks activities but its potential wide-ranging impact should not be underestimated. As Barings so visibly demonstrated, operational problems in a
16、financial institution can be life-threatening probably to a greater extent than operational problems in many other businesses.At the other end of the spectrum lie a whole range of market-related strategic risks, for example, the threat that supermarkets will increasingly capitalise on their existing
17、 customer relationships to gain a larger share of the retail financial services market, or that closing down bank branches in rural locations will trigger accusations of a lack of social concern and damage the banks public image and possibly its brand value even though the decision may be financiall
18、y supportable. With market concentration growing at national, regional and global levels, it is also essential in many cases not only to select the right strategic partner for growth but also to ensure relevant deals can be successfully concluded. Identifying the take-over candidate or strategic all
19、iance partner is but the start of the process. Care needs to be taken to manage the risk associated with regulatory intervention and to avoid the emergence of a hostile bidder to an agreed deal. As a number of British financial institutions have discovered in recent years, the price in terms of cont
20、inued independence of a high profile abortive deal can be high.Keep control of your reputationReputational risk is a major issue for the entire financial services sector, given the fundamental need for customers to believe in the stability and security of an organisations operations if they are to c
21、ontinue trusting it to handle their affairs. Furthermore, as the pensions mis-selling affair demonstrated there is a need for trust both in the individual institution and in the sector as a whole of which it forms part. This therefore calls on some occasions for collaborative as opposed to solely co
22、mpetitive risk management strategies as may also be the case in, for example, combating credit card fraud or on some IT security issues. In retail banking the reputation of individual banks could become much more of an issue in the years ahead with customers being increasingly tempted to consider th
23、e advantages of switching between high street banks, both as a result of the costs of switching being reduced and due to the influx of new market entrants. The recent questioning of the independence of analysts forecasts will also need to be addressed robustly if long-term reputational repercussions
24、 are to be avoided.Assessing the importance of risksIdentifying the existence of potential risks does not necessarily mean that action is required to mitigate all of them. Risks must be prioritised, by means of assessing the likelihood of their occurring and the extent of their impact high likelihoo
25、d and high impact suggesting high priority for action.Verifying your judgementsWhen identifying and prioritising risks, financial institutions need to have regard to the concept of “verifiability”; in other words, if a different group of people were making the same decisions about the importance of
26、those risks, would they be likely to come to the same conclusion? This is obviously more likely to be the case if a wide range of people from a broad cross-section of the business, both laterally and vertically, is involved in the risk identification and assessment process and if there are no “taboo
27、” subjects which prevent conventional wisdom within the organisation being challenged when necessary.External views of risk must also be fed into the identification and assessment process. What is the markets view of interest rate developments? How are personal investments expected to change in the
28、coming years? In the case of regulated areas such as financial services, the organisations perceived view of how its principal regulator views it will be of interest but also an assessment will be needed of how the overall regulatory environment is likely to develop, including in competition terms,
29、and the impact of international developments such as those being brought about by the Lampfalussy report in the EU.Change managementOne of the key challenges running across the entire process of identifying and assessing risks is that the business and financial world is in a constant state of flux.
30、How is the emergence of Internet banking changing the way that retail customers interact with their bank? How important is 24-hour access to account details? What does this mean for the maintenance of IT systems? Do people really want to be able to change their bank details using their mobile phone?
31、 How do you manage call centres effectively to ensure that this new form of bank/customer interface maintains the banks brand values?Some new or changing market conditions will develop gradually over time, while others may sweep the market quickly. Given this dynamic background, the internal control
32、 framework must be regularly reviewed and adjusted to take account of changing market conditions. It is managements role to recommend policies for managing risk, the boards role to review and approve them, and managements role once more to implement them and report back on their operation.Coping wit
33、h risk in the midst of change is particularly key when an industry is going through a period of consolidation. Merger and acquisition activity brings inevitable disruption as previously distinct cultures and systems are consolidated into a new combined entity. The risk management implications of suc
34、h proposals need to be carefully considered before, during and after the merger process.Embedding risksThe ability to respond to changing conditions largely relies on the internal control system being embedded in the banks operations. This is a complex process involving a range of activities includi
35、ng the effective communication of, and reporting on, the banks risk management policies at all levels, the development of risk training courses, the involvement of staff in responding to early warning systems, channels for reporting suspected control breaches and generally the creation of a positive
36、 risk management culture.The process of embedding risks should not, however, be allowed to lead to complacency or passivity within the organisation. The fact that systems are in place, a control manual exists and staff have been trained in risk management as part of their daily activities does not m
37、ean that systems are infallible as they will always be dependent, at least to some extent, on the people operating them and, for example, when staff morale is low more mistakes, accidentally or deliberately, are likely to occur.Cultural challengesCulture is also key in terms of creating an environme
38、nt where dealing losses and real or suspected control breaches can and will be reported. If the prevailing culture is one of blame without just cause, then there is a high chance that individuals will see it as in their own self-interest to try to cover up problems. Many organisations are also now d
39、eveloping “whistleblowing” procedures to ensure concerns can be reported confidentially.Remuneration issuesThe banks remuneration policies have an important role in reinforcing or undermining the internal control environment. Take the bonuses paid out at the end of each year. The factors determining
40、 the size of the payout are likely, indeed intended, to shape employees behaviour. Consider the trader who has had a bad patch and whose bonus is under threat. He/she might react by taking increasingly greater risks in the attempt to reach his/her target. Alternatively, he/she might lose interest in
41、 his/her performance until the start of the next bonus period. Either way, the banks overall performance could be affected by his/her actions. However, if the bonus is based on long-term performance, then he/she is far more likely to maintain an optimal effort level over the longer term.Management,
42、not eliminationThe Turnbull approach emphasises risk management, not risk elimination. Financial institutions must take risk, but they must do so consciously. Establishing the appropriate cultural framework needs the support of all staff in the process of identifying, monitoring and controlling risk
43、s. Risk management must be seen as an ongoing and valued activity with the board setting the example. It is without doubt a challenging agenda.Source: Anthony Carey, 2001.“Effective risk management in financial institutions”. Journal of Risk Finance. February.pp.24-27.译文:在金融机构的有效风险管理摘要:风险管理在金融部门中比经济
44、的其他部分更重要。但要进行风险管理是较为困难的。银行业和其他类似的金融机构的基础部门是在不确定的情况下采取风险的。如何描述特恩布尔报告作者是项目策划人,他创建了一个新的基本方针来处理风险。并提供了一个使各种特恩布尔想法成为风险管理的基石,建议他们如何能够发展指南。如果有的话,可以有些这种风险管理比金融部门更为重要的部分经济。金融机构对大量的世界领先公司发挥着作用,并且在每个国家的经济中扮演着关键角色。至此,在整个世界经济秩序中金融机构都发挥着作用。它们的整个业务都集中在不确定的情况下采取风险。特恩布尔报告对风险管理和内部控制方面进行阐述,它是适用于英国所有上市公司。并且它已在国际上广为广为传播
45、,以至于国际上对于特恩布尔报告的基本观点有充分的认识。特恩布尔报告的重点是有效的风险管理,而不是消除风险。在现代充满竞争性的市场经济中,企业组织如果一味的回避风险,那么这个企业也不可能获得理想的回报。另一方面,极不稳定的回报也是不可能有利于资本市场,对此忧虑很正常,尤其是坏消息。此外,特恩布尔方法是指导企业做正确的事情而不错过战略机遇,就如对于一家公司来说,它要实现其全部潜力就必须做正确的事情。应用特恩布尔方法可能导致一些金融机构意识到他们并没有采取足够的冒险行为,从而可能促使他们拓展一个新的市场。并且伴随着企业刚进入这个也许充满风险的新市场的同时,也意味着企业在这里也获得了开拓先锋的重大优势
46、。一种框架,而非一本规则手册特恩布尔报告还认识到了自然市场的动态性。在这自然市场中,一个企业组织的运作旨在鼓励企业建立风险管理系统,以促使企业能够不断地适应变化莫测的情况。为了避免他们自己把特殊控制看成一种终结,甚至一度终止了它们的用处,于是,这特恩布尔指导方针坚决地将内部控制用于他们更广泛的业务背景中:它们只在帮助企业控制那些威胁企业取得业务成绩的风险时才能体现价值。总之,特恩布尔提供了一个框架每个组织可以根据自己的情况制定适当的内部控制系统,而不是一个规则手册。合理判断的重要性特恩布尔回避标记框方法深受企业界的承认的事实,然而,这意味着从董事会层面开始,判断在建立有效的内部控制系统中起着重
47、要的作用。确保判断是合理的,也许是风险管理中的最大单一的挑战。如果对商业决策的判断根据不足,那么没有系统和没有内部控制量可以防止金额损失。判断来自于初步建立明确的业务目标,明确实现这些目标所承受的风险,优先要考虑那些风险所构成的威胁有多大,然后确定所要发展的内部控制系统的形式,并作出适当反应。判断还要结合运用成本效益分析方面,以采取具体控制方面的优点。这显然对于银行发放贷款之前所承担的信用检查来说是值得的,但成本效益方式将促进系统着眼于潜在的高风险贷款的工作人员的时间以及发展早期预警系统。当贷款不履行时,我们会采用成本效益方式而不是选择一个放之四海而皆准的方法。识别问题风险能对金融机构目标产生
48、威胁,其威胁范围从高度的特定功能风险到战略的,大场面的问题。我们考虑某一大银行的外汇交易活动。对于个体交易者,这交易活动显然是有风险的,任凭内部控制怎么运作自由,还是能造成重大损失。这种风险是存在于该银行交易活动的某一确定的部分,但其潜在的广泛影响不应该被低估。正如巴林银行所明确的表明那样,金融机构的运作问题比其他许多业务的运作问题更大程度上可能能危及生命。在频谱的另一端存在与市场有关的一系列战略风险,例如,市场所受到威胁如超市将会越来越多地利用它们现有的客户关系,以获得对零售金融服务市场较大的份额,或关闭在农村地区的银行分行的行为将引发世人对银行缺乏社会关注的指责和损害银行的公众形象或者也可
49、能损害品牌价值,即使这决定是得到财政支持的。随着市场密集度在国家,地区和全球各层次范围内的增长,选择适合战略合作伙伴,以及确保相关的交易可以顺利完成,这两点在许多情况下是很重要的。确定接管候选人或策略联盟伙伴仅仅是这一进程的开始。需要注意与管理介入相联系的管理风险,以及要避免和一个敌对的投标人商定的协议。作为许多英国金融机构,最近几年发现,在失败交易的高调处理继续保持独立性方面,价格可以抬高点。控制你的声誉声誉风险是整个金融服务的主要问题,如果要使客户继续信任金融组织来处理自己的事务,那么需要为客户提供一个基本需要,使他们对金融组织运作的稳定性和安全性产生信任。此外,正如退休金不当销售的事件证明金融运作不仅需要个体机构的信任,也需要全体组成部门的信任。因此,这要求对一些事情可以采取合作,而不是纯粹竞争性风险管理策略,比如,在打击信用卡欺诈或一些IT安全问题上。在零售银行业中的个体银行的声誉问题可能在未来数年中会成为客户越来越多地倾向于考虑高街银行间转换优点的原因,并且因为个体银行的声誉和涌入新市场的人员的增多而导致交易成本的降低。如果要避免长期的声誉的影响,那么需要坚决解决对最近分析师预测的独立性的质疑问题。评估风险的重要性确定潜在风险的存在性不是必需的,这意味着我们需要减轻所有潜在的风险的行动措施。风险
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