Consult Improving Bank Risk Management Article

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Improving bank risk management: Seizing business benefits

Executive summary Bank profits are highly dependent on core risk management capabilities. During the recent market turmoil, many banks recognized the need to improve their risk management function to enhance their bottom line. Unfortunately, too many banks have not acted with enough aggressiveness or rigor to identify and implement improvements. Our experience suggests that banks can achieve improvements that significantly exceed the necessary investment by investing in the following initiatives: 1. Clearly delineate risk management, measurement, and monitoring responsibilities. 2. Validate risk models, review risk systems, and test risk models and mitigation strategies with independent resources. 3. Employ statistical methods to clearly define drivers of risk ratings and capital parameters. 4. Establish a governance structure that assures the control of data and information. 5. Streamline and automate credit risk rating and scoring processes. 6. Re-engineer and automate risk system business processes. 7. Consolidate operational risk data in a centralized repository. Bank management needs to move expeditiously, but smartly to realize the operating benefits available from these initiatives. At the end of this article, we have provided a brief action plan for defining and launching a series of initiatives that meets your banks risk management needs. The business case for adopting risk management improvements Direct business benefits A strong business case exists for implementing improvements in bank risk management functions as soon as possible. For discussion purposes, assume there is a U.S. bank with $10 billion in assets and a $7 billion loan portfolio. A bank, such as this, could realize total potential annual earnings benefits in the range of $8 to $18 million from credit risk improvements alone. The primary drivers of these benefits are: Connect with us: For more information or any questions you might have on improving your risk management, please connect with us at connecting@bakertilly.com or 800 362 7301.
> Approximately a 25 to 40% productivity increase in origination, risk rating, credit approval, portfolio
management, data management, and management and regulatory reporting. This productivity increase delivers reduced payroll, occupancy, and other headcount driven expenses. The range of benefit is from $1.5 to $3 million per annum. Given the labor intensity and lengthy effort associated with certain functions such as risk rating and credit approval, we would expect productivity improvements at the top of the range. from $7.5 to $15 million per annum. Again, a more automated and standardized risk rating process, coupled with similarly equipped portfolio monitoring and account management processes, can significantly reduce loan losses, from both under-informed decisions and operational failures.
> Approximately a 15 to 50 basis point reduction in loan loss levels equates to a range of benefits
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As better information and risk rating tools can be used to price more consistently with risk, where the market allows, benefits can be generated through improved pricing. Even for banks where major information technology improvements are needed (e.g., risk rating model enhancements, data warehouses, credit origination systems, etc.) to enable benefit realization, these initiatives can produce payback within a 2 to 3 year timeframe. This is based on an estimated investment in the $15 to $20 million range. Key areas of transformation We focused on two credit and operational risk screening criteria to guide the selection of key transformation initiatives:
> Low cost to design and implement risk management functionality primarily changes in policies
(for this article policies include procedures and standards), process, responsibilities (for this article responsibilities include roles, accountabilities, and authorities), and people skills; or readily available packaged software. credit losses include those due to operational failures), and other operational losses.
> Large benefits from improved revenues, lower operating costs, lower credit losses (for this article,
We identified seven initiatives that satisfy these criteria. In developing the initiatives, we made an effort to focus on relatively low cost enhancements that are primarily non-technology changes, such as processes, policies, and roles. We do recognize that the technology building blocks of the risk management infrastructure are often weak or missing, and these technology needs must be addressed to realize the full $8 to $18 million of annual benefits. However, our experience is that almost half of the benefits can be achieved prior to making the technology related investments. Subsequent investment in technology will then formalize the processes and policies, and assure the continuation of good practices. Additionally, the enhanced technology can enable faster and more consistent practices as well as better monitoring and analysis. And as an added benefit, by first enhancing and better defining critical risk management processes, policies, and roles, the business requirements for the enabling technology and the designs to support the functions will be more clearly defined and implementation less difficult. Clearly, each institution will be different in the amount of technology related effort that would be required. Each banks risk management operations are different and will result in a different set of key initiatives. Most banks will benefit from applying these concepts, sized to their relative scope and scale of business. Many of the high pay back initiatives do not require large technology projects, but even the ones that do, contribute to more precise modeling of risks and parameters and lower operating costs. 1) Clearly delineate the risk management responsibilities of the Board of Directors, and senior and middle management with respect to both operational risk and credit risk governance functions. Enhanced oversight of risk management across the bank should improve the execution of risk management functions and processes and thereby reduce operational and credit losses. The effort to accomplish this should be relatively low; basically consisting of the effort required to design policies and responsibilities for directors and management, and train directors and management.
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For the executives involved to be able to accomplish what is expected of them, they must be provided with the information necessary for effective decision-making. This requires the bank to provide greater transparency to internal and external stakeholders through automated reports to monitor risk trends (e.g., concentrations, risk rating migration, etc.). Providing improved information on trends and issues in the various risk areas will enable the Board and management to be more insightful in the guidance they provide and the decisions they make. The cost of providing improved automated reporting against whatever information exists should be low to moderate. Obtaining, scrubbing, and storing enhanced information is discussed below. 2) Establish and ensure execution of periodic independent validation of risk models, review of all risk systems, and comprehensive testing of risk models and risk mitigation strategies. The primary effort involved in an annual review (which should include the overarching review by internal audit) is to: (a) establish policies and processes for the review of risk systems, including on-going, independent validation of models for estimating parameters, credit risk rating, and operational risk; and (b) establish policies and processes for testing model performance and results through scenario tests, sensitivity tests, stress tests, and back-tests. These capabilities should reduce unexpected credit and operational risk losses due to closer adherence to policies for operating and maintaining risk systems. Enhanced validation and testing will result in more accurate and more consistent tools for measuring, monitoring and, ultimately, managing credit and operational risk, which should result in lower unexpected losses. This is particularly important in economic downturn conditions, as the bank will realize enhanced ability to test capital adequacy and the effectiveness of risk mitigation strategies. The costs to implement these capabilities should be low to moderate, depending on what capabilities the bank already has in place. Developing policies and processes for the annual review and conducting the review should require a modest effort. Establishing a validation team (distinct from the people who develop and use the various risk models) within the risk management department would be moderately expensive and may require hiring external consultants for an annual review. Other changes, such as scorecards and standards for work products and methods, would be small investments. 3) Employ statistical methods to more clearly define drivers of risk ratings and capital parameters. We recommend the bank:
> Rely on internal (to the bank) historic data, especially on defaults and losses, to drive credit
management and pricing models. While it may require as much as 15 to 20 years of history across two full business cycles (or more) to be able to generate the highest quality forecasts, 4 to 5 year of history will provide results that represent a good start. Using internal data will produce more accurate risk rating and credit scoring; this will enable more insightful decisions with respect to pricing, collateral requirements, and credit approvals (better return for credit risk taken). Similarly, operational risk management relies heavily on internal loss data and carefully supplements it with external loss data for validation (and not usage) purposes. risk rating models, scoring models, and parameters, including standard definitions for the probability of default (PD), and loss anticipated in the event of default (LGD). Larger banks may also develop in their models an estimated for the likely exposure at default (EAD). In addition, ensure the use of a common set of definitions of collateral types. A more precise and formula driven risk rating system will be less expensive to operate, monitor, and update, and will produce fewer rating surprises and unexpected losses. Embedding the definitions in the data acquisition systems will result in more accurate measurement of actual economic losses and defaults. If the banks special loans tracking/
> Employ statistical methods to identify the specific drivers and quantify their relative importance for
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accounting systems already capture the cost items required for LGD, the banks investment can be quite modest as simple as adding one or more quantitative personnel to the risk rating, scoring, and parameter modeling teams. However, if additional data items need to be collected regarding special loans, then the cost would be somewhat higher.
> Employ simple statistical methods for operational risk. Use frequencies and severities of actual loss
data to calculate expected operational losses and deploy multipliers that directionally account for exposure (e.g., higher multipliers in the wholesale banking sector where operational losses are less frequent and more severe versus the retail banking sector where the opposite is the case, etc.). By employing tools that monitor continuously and update automatically, the bank will experience more accurate models that produce better underwriting and account management decisions, better pricing, and better control of losses. However, with respect to operational risk, we again recommend keeping it straightforward. This risk class is emerging and not as sophisticated or precise as credit or, certainly, market risk. Develop metrics that correspond to key controls to ensure that risks being managed can be measured.
> Utilize automated tools to monitor and update the scoring, risk rating, and parameter models.
4) Establish a governance structure that assures the control (e.g., acquisition, adjustments, reconciliation, etc.) of data and information. Oversight of data quality, active data management, and the transformation of data into actionable information are keys for monitoring the banks risk profile and trends, as well as for use in modeling. Data governance is crucial to achieve reduced credit and operational losses, and will also help drive operating cost decreases. The associated costs should be relatively low, with effort required to design policies and responsibilities for personnel in oversight functions, and to train affected personnel. Information and data are at the heart of the risk management function. Improving the quality and quantity of data available will reduce unexpected errors in the risk management models and reduce operating costs. Capabilities to acquire, scrub, store, and make available in a timely fashion the improved information will enable more accurate and timely reporting and monitoring and, thereby, reduce unexpected losses that have historically resulted from slow responses to emerging risk situations. Depending on the banks existing environment and the approach it chooses, the costs associated with improving the data available for risk management can fall within a very wide range. The benefits that the bank may be able to realize will also fall in a fairly wide range. Thus, bank that want to maximize the value-for-cost equation, will follow less rigorous and less costly approaches to data; for instance, using non-production databases until the right volume of data is available. However, the bank following this approach will likely need to deal with data that is less complete and less accurate. The bank may also need to translate internal paper files to electronic form, and validate and supplement existing data. While creating a robust data infrastructure to obtain, store, and control the data can be a significant effort, especially if changes are required to source application systems, banks can accomplish this over time in bite-sized-chunks, thereby limiting the cost in any time period.
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5) Streamline and automate credit risk rating and scoring processes Perhaps the areas with the largest opportunity for realizing business benefits are the processes of analyzing credit risk, rating corporate and commercial credits, and scoring consumer and some small business credits. All banks should consider the following initiatives:
> Streamline and automate application taking and risk rating processes for commercial and corporate
credits. This will allow faster, more consistent credit decisions and risk ratings, resulting in fewer unexpected loan losses, and reduced operating costs. Using automated tools for taking applications and scoring individual and small business loans can significantly improve originator and underwriter productivity, consistency of credit decisions, and loan portfolio profitability. We anticipate that banks could achieve 25% or more reduction in operating costs, and up to 50 basis points of reduction in loan losses. Additionally, there should be reduced credit losses due to operational failures. There may be moderate costs incurred to achieve the benefits, primarily from purchasing vendor supplied software for risk rating and scoring. managing, measuring, and monitoring the credit pipeline (e.g., origination, risk rating, approval, documentation, booking, account management, servicing, collections, recovery, pay-off, etc.). These functions can usually be improved significantly in terms of operating costs because of improved speed and consistency of documentation preparation and booking. In addition, we often see reduced losses arising from incomplete documentation and other operational failures. The effort required to realize the benefits should be relatively low and be comprised of the effort to evaluate documents and policies related to loan documentation and controls.
> Standardize loan documentation, and streamline and standardize processes and policies for
6) Re-engineer and automate risk system business processes Many front-to-back office productivity gains can be realized with improved risk information and tools. Each transformation area discussed previously will require careful integration for effective and efficient risk management performance. Beyond them though, there are many other opportunities to explore. Consider, for example, the potential transformation impact on responsibilities for relationship managers. They can free up time for selling by streamlining commercial customer account review activities in several ways, including:
> Streamline account reviews by allowing relationship managers or underwriters to focus their review
efforts on a smaller, well-defined set of risk rating drivers, whose relative contributions to risk rating have been empirically established. system with common information databases and tools. Access to relevant information will be easier and many account monitoring activities can be delegated from individual relationship managers to a centralized scaleable environment. Newly available time could then be devoted to revenue enhancing sales activities.
> Support account and portfolio management activities that are currently siloed by product or source
Another opportunity to consider should be that newly available risk information and predictive analyses can reduce direct losses as well as loss handling costs. Risk information and tools introduced to underwriting and portfolio-monitoring processes will generate process efficiencies. Similarly, improved RAROC information and data warehouse delivered customer information will enhance the ability to deliver more tailored pricing propositions, thus increasing sales effectiveness. Default and
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loss characteristics at a pool, borrower, and facility level, as well as by product and market segment, allow an institution to identify high and low risk customers and exception price accordingly. Strategic risk levers that influence pricing such as an institutions product penetration to a customer, cross product netting, and collateral values, will be more transparent with advanced data warehouses. Portfolio stress testing analyses and resulting risk appetite/capital adequacy decisions could then be operationalized through portfolio and customer level pricing.
Business Benets of Strategic Risk and Capital Planning
Prot enhancement
Strategic risk and capital planning
Time and effort
Revenue improvement
Marketing and sales
Pricing
Cost reduction
Reduced losses Regulatory capital
Productivity
Strategic intent
Often times these choices determine the extent of new or radically changed automation. In our experience, the most significant components of cost are likely to be driven by investments in new data warehouses, enhancements to source application systems, and risk management application systems. Information technology needs to be fully engaged and aligned with risk management to enable the bank to harvest the available benefits. Costs to automate and re-engineer processes are likely to be moderate to high due to the broad scope of risk management systems and the many processes and policies that need to be examined and revised. 7) Consolidate operational risk data in a centralized repository comprised of modules (e.g., internal losses, external losses, scenarios, metrics, etc.) A separate operational risk information system should exist in the bank. It is most probable that operational risk data exists in the bank. However, the bank is likely to face some data challenges in designing and implementing the required system solution. These challenges may include, among others: (1) inconsistent methods of data collection across sectors and functions, (2) data fragmentation among operational risk databases, (3) the need to transform operational risk data to information, or (4) insufficient loss history or scenarios to develop reliable multipliers. Some vendors are shopping system solutions to industry participants. However, our experience suggests that banks may be better off leveraging in-house solutions. Many of the vendors solutions tend to lack flexibility, which requires banks to fit their data to the application, rather than adapting the application to fit the data requirements. In addition, the majority of offerings have been developed with a strong bias to dimensions of either a quantitative (e.g., losses, scenarios, metrics, etc.) or qualitative (e.g., risks, deficiencies, etc.) operational risk program, whereas most banks recognize that they need to balance quantitative and qualitative dimensions.
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Next steps This article provides a menu of opportunities available to banks of all sizes to improve their risk management capabilities and performance while improving operating results. A valuable by-product of accelerating selective improvements will be reduced project execution and/or implementation risk resulting from concentration of change efforts into massively complex programs and decreased needs for large numbers of high-cost external resources. The magnitude of change and investment will be unique to each institution. Effort and cost will be dictated by the size of the gap between current risk management capabilities and the banks desired end-state capabilities goal. Direct business benefits can be extensive and range from tactical to strategic in nature. Realization will be dependent on the institutions appetite for change and aggressiveness in pursuing a return on investment. As banks anticipate large change projects to improve performance and become compliant, they are appropriately concerned that their approaches avoid mistakes and create unnecessarily disruptive cultural challenges. A large share of the spending associated with our recommendations is technology related. We believe significant economies are not being realized today. Many larger banks often choose customized solutions for most of the technology, while others do off shore building to reduce costs. However, we think there are package solutions that can be customized to address risk rating tools, model monitoring, and even data base construction that can significantly lower costs and accelerate construction for banks of all sizes. As highlighted previously, management needs to move expeditiously, but smartly, to realize the operating and regulatory benefits of enhanced risk management by:
> Conducting a candid assessment of likely productivity gaps across all portfolios, and initiatives
in progress.
> Developing a cost effective, but realistic set of initiatives and time line containing a critical path,
measurable interim milestones, and implementation dates.
> Encouraging key executives to take ownership of the initiatives and launch the program with full
commitment to support these efforts with prime organization resources and external support, as needed.
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Pursuant to the rules of professional conduct set forth in Circular 230, as promulgated by the United States Department of Treasury, nothing contained in this communication was intended or written to be used by any taxpayer for the purpose of avoiding penalties that may be imposed on the taxpayer by the Internal Revenue Service, and it cannot be used by any taxpayer for such purpose. No one, without our express prior written permission, may use or refer to any tax advice in this communication in promoting, marketing, or recommending a partnership or other entity, investment plan or arrangement to any other party.
Baker Tilly refers to Baker Tilly Virchow Krause, LLP, an independently owned and managed member of Baker Tilly International. The information provided here is of a general nature and is not intended to address the specific circumstances of any individual or entity. In specific circumstances, the services of a professional should be sought. 2010 Baker Tilly Virchow Krause, LLP
Appendix
We believe that banks need to focus their efforts on carefully redefining these core capabilities to create quantum improvements in their risk management productivity and quality. The following graphic presents the scope of risk management capabilities and related functions that were considered in this article. The graphic further presents the life cycle of data from its definition and recognition to fulfill business objectives through its final stage as information used to fulfill control, monitoring and reporting requirements
Policies, Guidelines, and Standards Oversight and Strategy
Corporate risk system oversight > Policy compliance > Effectiveness of rating systems and processes > Internal control review Strategy > Customer, product, and channel strategy and objectives > Regulatory interpretation and risk framework > Risk appetite and capital planning
Process and Procedures

Portfolio monitoring, capital adequacy, and regulatory reporting
Controls, Monitoring, and Reports
> Capital adequacy denitions > Risk concentration and > Exposure monitoring and >
migration standards Equity and securitization frameworks testing framework
> Strategic capital planning > Capital adequacy calculation > Customer and product risk segmentation > Risk concentration analysis and testing > Special loan and receivable management > Pillar 3 disclosures
Risk modeling and validation analysis
> Risk rating migration > Risk prole and capital adequacy > Regulatory and economic capital > Capital stress testing results > Regulatory reports
Skill Sets / Roles and Responsibilities / Division of Duties
> Modeling design, methods, and > > >
Data maintenance
> Data management and control >

framework Data quality and integrity
> Data collection > Data processing > Data retrieval and storage > Data delivery
Credit and collateral management (loans, leases, securitization, trading, equities)
> Data error and linkage breaks > Data cleansing/reconciliation > Data lifecycle change history > Data model validation
> Collateral denition, controls, and > >

valuation Loan covenant denition and monitoring Risk system operation and application
> Risk rating/credit approval > Collateral management and monitoring > Default management
> Collateral concentration and trends > Timeliness (e.g., collateral updates) > Exceptions (e.g., covenants, > Defaulted loan post mortem
assessment policies)
Operational, reputational, and strategic risk
> Risk systems and standards > Risk control points
> Operational risk system validation and verication > Risk self assessment > Operational risk system development and
maintenance
> Risk exposures > Risk assessment results > Losses
Enabling Technology
standards Validation, vetting, and use test criteria Rating/parameter system design Annual review methodology
> Rating/parameter development and maintenance > Model development and maintenance > Rating/parameter validation, vetting, and testing > Model validation, vetting, and testing
> Risk rating process, parameter, and > Overrides/exceptions > Backtest results (e.g., losses) > Geographic/industrial consistency
calculation changes
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Key opportunities for transformation
The analysis covering transformation opportunities outlined below in a cost-benefit matrix is based on our extensive consulting experience and banking industry studies. Each banks current risk operations are different and will result in a different set of key initiatives. We see that larger banks, in general, reap sizeable benefits in reduced operating costs and lower risk related losses. Many of the high payback initiatives do not require large technology projects, but even the ones that do contribute to more precise modeling of risks and parameters, and lower operating costs.
Key Areas of Transformation Ratio of Benefits to Cost
Comments on Costs and Benefits
Strategy, oversight, reporting, monitoring, and capital adequacy
Clearly delineate the risk management responsibilities of directors, and senior and middle management Establish an independent annual review of risk systems
5:1
Benefits: Reduced credit and operational losses Costs: Effort required to design policies and responsibilities; and train directors and managers Benefits: Reduced credit and operational losses Costs: Effort to design policies and responsibilities for the annual review and conduct the annual review Benefits: More insightful guidance for management, the Board, and regulators (this is the comprehensive list, reports were not a high priority initiative) Costs: Construction of automated reports Benefits: In extreme conditions assure model accuracy, capital adequacy, and effectiveness of risk mitigating strategies Costs: Effort from managers to develop scenarios and risk managers to test models and risk mitigation strategies Benefits: More accurate forecasts of loss behavior Costs: Resources to acquire data and build databases; 15 to 20 years of history Benefits: More precise models, less expensive to operate, lower losses Costs: Add quantitative personnel to modeling teams
4:1
Provide more automated reports to monitor risk trends (e.g., concentrations, risk rating migration, etc.)
5:3
Test model performance and results using scenario, sensitivity, stress tests, and back-tests
2:1
Risk modeling and validation
Rely on internal historic data (especially defaults and losses) to drive credit management and pricing models Employ statistical methods to determine model drivers and their importance for risk rating, scoring, parameters
2:1
5:2
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Key Areas of Transformation
Ratio of Benefits to Cost
Adopt standard definitions for PD, LGD, and update/ establish systems for capturing data Utilize automated tools to monitor and update the scoring, risk rating, and parameter models
4:1
Benefits: More accurate measurement of economic losses and defaults Costs: Effort to enhance loss tracking systems to capture added loss data Benefits: Better loss management from improved models for underwriting, account management, pricing, and operational risk Costs: Resources for acquiring and tailoring automated tools used to monitor and update models Benefits: More accurate measuring and managing of credit and operational risk; reduced credit and operational losses Costs: Effort to define validation scorecards, products, and methods; and establish and train a validation team Benefits: Reduced errors of risk management models due to improved data Costs: Resources needed to acquire external data, translate paper files to electronic files, and validate and supplement existing electronic data Benefits: Reduced time and operating costs to populate databases, more accurate and timely reporting, reduced risk related losses Costs: Resources for automating interfaces and updating control processes Benefits: Improve data integrity for reduced credit and operational risk losses Costs: Effort required to design policies, standards, and roles for overseers, and train overseers
5:4
Establish independent validation of models for parameters, credit risk rating, and operational risk
2:1
Data maintenance
Gather high quality, accurate internal historic data and appropriate external data 2:1
Ensure processes and interfaces are in place to acquire current risk management data in a timely manner Establish a governance structure that oversees acquisition, adjustments, and control of data
4:3
4:1
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Key Areas of Transformation
Ratio of Benefits to Cost
Credit and collateral management
Standardize loan documentation; streamline processes and policies for controlling the credit process pipeline (e.g., origination through pay-off, etc.) Streamline and automate risk-rating processes for commercial and corporate credits
2:1
Benefits: Reduce losses arising from incomplete documentation; improve the speed and consistency of document preparation and booking Costs: Effort to evaluate and redesign loan documentation, policies, and controls Benefits: Streamlined, automated processes for faster, more consistent credit decisions and risk ratings; resulting in fewer unexpected loan losses Costs: Simplify data requests from customers; acquire vendor risk rating software Benefits: Improve originator and underwriter productivity, consistency of credit decisions, and loan portfolio profitability Costs: Acquire vendor software for taking applications and scoring loans Benefits: Reduced risk related losses and operating costs Costs: Effort to examine, revise, and automate processes and policies Benefits: Enabler for timely, proactive, and accurate decision making; optimized deployment of operational risk capital; reduced operational losses; assurance of regulatory compliance Costs: Effort and modest investment in building repository to receive feeds from current operational risk information databases
5:3
Higher share of scored credit decisions for consumer and small business
5:1
Re-engineer and automate risk system business processes

Operational risk
5:3
Consolidate operational risk data in a centralized repository 5:2
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Management Consulting Insights

Improving bank risk management: Seizing business benefits

Management Consulting Insights

Management Consulting Insights

An independent member of Baker Tilly International

Management Consulting Insights

Management Consulting Insights

Management Consulting Insights

Time and effort

Marketing and sales

An independent member of Baker Tilly International

Management Consulting Insights

Management Consulting Insights

Process and Procedures

Controls, Monitoring, and Reports

> Modeling design, methods, and > > >

> Data management and control >

> Collateral denition, controls, and > >

Operational, reputational, and strategic risk

> Risk systems and standards > Risk control points

> Risk exposures > Risk assessment results > Losses

Management Consulting Insights

Key opportunities for transformation

Comments on Costs and Benefits

Strategy, oversight, reporting, monitoring, and capital adequacy

Risk modeling and validation

Management Consulting Insights

Key Areas of Transformation

Ratio of Benefits to Cost

Comments on Costs and Benefits

Management Consulting Insights

Key Areas of Transformation

Ratio of Benefits to Cost

Comments on Costs and Benefits

Credit and collateral management

Re-engineer and automate risk system business processes

Consolidate operational risk data in a centralized repository 5:2

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