A bank should develop a framework for managing operational risk and evaluate the adequacy of capital given this framework. The framework should cover the bank’s appetite and tolerance for operational risk, as specified through the policies for managing this risk, including the extent and manner in which operational risk is transferred outside the bank. It should also include policies outlining the bank’s approach to identifying, assessing, monitoring and controlling/mitigating the risk.
The Capital Requirement Directive, recently published, requires this operational risk (OR) framework to be subject to regular internal (or external) audit review.
So, internal audit should include in its annual plan the complete review of the framework for managing OR, and the review of the policies, process and procedures for identification, assessing, monitoring and control/mitigate OR.
However, meanwhile this independent review is key and, as Sheen (2005) states, it could provide a valuable challenge to the OR framework, there may be a need for greater focus on it.
The Financial Services Authority’s (FSA) paper “Operational risk management practices” which provides feedback on eight firms visited, noted that “In general, firms had not yet established processes to assess the effectiveness and adequacy of their OR frameworks”.
In the main banks visited, internal audit had not yet reviewed firms’ OR approach, although auditors indicated that they would carry out a review in the future, once the OR framework was more embedded.
The board of directors should ensure that the bank’s OR management framework is subject to effective and comprehensive internal audit by operationally independent, appropriately trained and competent staff. The internal audit function should not be directly responsible for OR management.
Its execution means that:
. On one hand, the board of directors should ensure that the staff of the bank’s internal audit department are appropriately trained and competent staff. Qualified staff is available to verify that operating policies and procedures have been effectively implemented and consequently to guarantee the effectiveness of the entity’s OR strategy.
In practice, internal audit at some banks (particularly small ones) may not have the necessary skills, and in these circumstances board of directors should consider whether this function should be outsourced.
. On the other hand, the board of directors should ensure that the independence of the audit function is maintained.
The audit function may provide valuable input to those responsible for OR management, but should not itself have direct OR management responsibilities. Nevertheless, in practice, particularly at smaller banks, the audit function may have initially held responsibility for developing an OR management program. Responsibility for day to day OR management must be transferred elsewhere in a timely manner, although problems may still arise if the audit function is required to validate the process they had originally established.
Internal audit should adapt its planning, objectives and procedures in order to ensure appropriate supervision of these systems.
So, the annual audit plan should include the specific review of the policies, processes and procedures for managing OR with the following objectives:
. The confirmation of the existence and level of implementation of policies and procedures, with respect to OR, approved by the board of directors.
. The review of the integrity of the OR identification process.
. The valuation of the effectiveness of the tools used for the OR assessment, as well
as the methodology and measurement approaches used.
. The adoption of a risk-based approach to the regular monitoring of the OR assessment throughout the different areas of the bank.
. The validation of the approach used for qualitative risk assessment and for regulatory capital calculation in the case of the advanced measurement approach or the review of the capital calculation inputs and deductions in the rest of approaches.