Don’t Let the SMA Kill OpRisk Modelling
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
A messy compromise that pleased no-one, one doesn’t have to look far for critics of the Basel Committee’s proposed standardised measurement approach (SMA) to calculating operational risk capital requirements.
Peter Sands, the former chief executive of Standard Chartered, recently claimed here that the SMA, as proposed, provides few – if any – incentives for banks to improve their management of operational risks.
The industry’s frustration with the operational risk capital framework is clear – and justified, given patchy implementation of the current advanced measurement approach (AMA), and the ill-conceived attempt to address that problem with the SMA. We agree with Sands’ characterisation of the proposed SMA as being too simplistic, exclusively backward looking and conceptually flawed. We documented our concerns when the first SMA draft was released by the Basel Committee; at the OpRisk North America conference; and in the Journal of Operational Risk.
But the current debate has become mired in confusion between the concept of capital for operational risk and the execution of that concept through the AMA. The fact that existing efforts have failed should not be misconstrued
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