Fraser Bank is comparable in size (market capitalisation) and in its variety of activities to
BWT Group. From headquarters level Fraser appears to be a monolithic, decentralised
banking organisation, with fairly autonomous business units such as investment, commercial,
and private banking. On the face of it, Fraser Bank’s risk management practices resembled
those at BWT. Risk was measured, managed and reported by silos and business units, giving
the impression of enterprise-wide coverage. There was a separate Economic Capital team and
a Risk Director, who sat on the executive board. Out of a crowded committee structure,
quarterly and monthly risk committee meetings emerged, with timely and increasingly
formalised reporting practices