Memo to Bank CEOs: Treat OpRisk with More Respect
Ariane Chapelle and Evan Sekeris
Introduction
Operational Risk in Four Letters
An Invisible Framework
Small is Beautiful in OpRisk Management
The Business Value of ORM
How to Minimise ‘People Risk’
The Missing Piece
Risk Appetite and Framework
From Russian Roulette to Overcautious Decision-making
The Importance of Preventive KRIs
How to Build Preventive Key Risk Indicators
Unlocking KRIs
Six Steps for Preventive KRIs
Have Your Cake and Eat It
Conduct, Not ‘Conduct Risk’
How to Manage Incentives
Is Reputation Risk Overstated?
What Regulators Want
Conduct & Culture
OpRisk Takes Forward Steps at OpRisk Europe 2014
Modern Scenario Analysis
The Rogue’s Path
Rogue Trading No Training: The Connections
What Brexit Teaches OpRisk
OpRisk Survey Shows the Insidious Effects of Political Risk
Discarding the AMA Could Become a Source of OpRisk
UCL Research Shows that SMA Reforms Introduces Capital Instability and Discourages Risk Management
Memo to Bank CEOs: Treat OpRisk with More Respect
Don’t Let the SMA Kill OpRisk Modelling
Recent criticism of the operational risk capital framework by two senior figures in the banking industry – Peter Sands, the former chief executive of Standard Chartered, and Jamie Dimon, chief executive and chairman of JP Morgan – has sparked much debate in the banking and regulatory community in recent weeks.
The comments were made at a watershed moment for the industry, with the revised op risk capital framework stymied by transatlantic regulatory (or perhaps, de-regulatory) politics, and seemingly increasingly unlikely to be agreed upon, let alone implemented. Dimon’s comments were even picked up by the wider financial press – a rare instance of operational risk being mentioned in mainstream media.
While some of the criticisms certainly have merit and deserve further debate, we fundamentally disagree with many of the arguments made by Sands and Dimon. Both critiques contain fallacies which are regularly made in arguments against op risk capital, and we believe both, as such, are fundamentally flawed.
Both Dimon and Sands expressed their strong reservations against, if not outright opposition to, the idea of holding dedicated operational risk regulatory capital. Dimon, in
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