Rizwan Chughtai

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    Rizwan Chughtai

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    Risk exposure arising from business activities

    Need to effectively manage because of

    Potential business losses

    Ensure business continuity

    Wider and/or complex risk requires moreprudent management

    Risk appetite determines risk exposure

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    Optimize risk-reward trade-off rather thanminimize/eliminate risk.

    Risk taking is inherent activity but

    neither engage in business with unnecessary risk norabsorb risk that can be transferred

    Regulatory Case vs Business Case

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    Strategic Level

    Encompasses senior management and BOD

    Macro Level

    Within a business area or across business lines

    Micro Level

    On-the-line risk management

    Need to have properly structured RM

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    Introduced in 2003 (BSD Circular 7 of 2003)

    Issued to enable financial institutions toestablish their own RM procedures

    Provide an overview of actions and notintended to detail every control procedure

    Flexible and adaptable with the size and

    complexity of business

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    Areas covered

    Credit Risk

    Market Risk

    Liquidity Risk Operational Risk

    Certain basic principles for risk managementapplicable to all institutions irrespective of sizeand complexity

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    Board and senior Management oversightTheoverall responsibility of risk management vests in the

    Board of Directors, which shall formulate policies invarious areas of operations of the bank. The senior

    management is, interalia, responsible for devising riskmanagement strategy and well-defined policies andprocedures for mitigating/controlling risks, which shouldbe duly approved by the Board. The senior managementis also responsible for the dissemination, implementation,and compliance of approved policies and procedures.

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    Integration of Risk ManagementAt operational level, risk assessment may be made on

    portfolio or business line basis, however, at the top levelthe management need to adopt a holistic approach in

    assessing and managing risk profile of the bank.

    Business Line AccountabilityIrrespective of a separate risk review or management

    function individuals heading various business lines orunits are also accountable for the risk they are taking.

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    Risk Evaluation/MeasurementWherever possible risks should be quantitatively

    measured, reported, and mitigated.

    Independent reviewThe risk review function should be independent of thosewho approve and take risk. The review should include,interalia, stress tests exposing the portfolio tounanticipated movements in key variables or major

    systemic shocks. Contingency planning

    Banks should have contingency plans for any unexpectedor worst case scenarios.

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    The individuals who take or manage risks clearlyunderstand it.

    The organizations Risk exposure is within thelimits established by Board of Directors.

    Risk taking Decisions are in line with the businessstrategy and objectives set by BOD.

    The expected payoffs compensate for the riskstaken

    Risk taking decisions are explicit and clear.

    Sufficient capital as a buffer is available to takerisk.

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    Board and Senior Management Oversight

    BoD to approve credit risk strategy and othersignificant policies

    SM to develop and establish credit risk policies &credit administration procedures and guide staff

    Setting up appropriate organization structureand specify duties/responsibilities

    Credit management discipline

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    Credit Origination

    Assess risk profile before extending credit

    Cash flows and repayment capacity

    Appropriate utilization of credit Limit Setting

    Credit Administration

    Documentation, Disbursement, Monitoring,Repayment, Credit Files, Collateral Documents

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    Measuring Credit Risk

    Internal Risk Rating

    Rating Review

    Credit Risk monitoring & Control

    Risk Review

    Delegation of Authority

    Managing Problem Credits

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    Board and Senior Management Oversight

    Organizational Structure

    Risk Management Committee

    Asset-Liability Committee

    Middle Office

    Risk Measurement

    Interest Rate, Foreign Exchange, Equity

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    Risk Measurement

    Repricing Gap Models

    Measuring Risk to Economic Value

    Value at Risk Risk Limits

    Gap Limits

    Factor Sensitivity Limits

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    Board and Senior Management Oversight

    Early warning indicators of liquidity risk

    Liquidity Risk Strategy

    Composition of Assets & Liabilities

    Diversification and Stability of Liabilities

    ALCO/Investment Committee

    Liquidity Risk Management Process

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    Liquidity Risk Measurement & Monitoring

    Contingency Funding Plans (CPF)

    Use of CPF for Routine Liquidity Management

    Use of CPF for Emergency & Distress Environment Cash Flow Projections

    Liquidity Ratios and Limits

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    Operational Risk Management Principles

    Ultimate accountability with BoD

    BoD to ensure effective & integrated OpRisk

    Management Framework BoD and SM to identify and define all categories of

    Operational Risk

    Document and communicate OpRisk policies and

    procedures Integrated business and support functions

    Diligence of business line

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    Risk Assessment and Quantification

    Risk Management and Mitigation

    Risk Monitoring

    Key Risk Indicators (KRIs)

    Risk Reporting

    Establish Control Mechanism

    Contingency Planning

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    Guidelines in 2004 (BSD Circular 7 of 2004)

    Properly designed and strictly enforcedsystem of internal controls helps:

    protect the organizations assets and profitabilityfrom operational losses and frauds and forgeries

    produces reliable financial and managementreports

    helps compliance with laws and regulations

    creates value for the stakeholders

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    BSD Circular 13 of 2004

    Need for comprehensive BCP arrangements

    Key considerations Responsibility Components of BCP

    Critical Business Line

    Geographic Concentration

    Centralization of Operations

    Recovery Time Targets

    Testing

    Updation and Validation

    Compliance

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    Need to have synchronized and adhesive policiescovering different areas

    Consolidated instructions on policy framework(BSD Circular 3 of 2007) Minimum Areas

    Risk Management Policy

    Credit Policy

    Treasury & Investment Policy

    Internal Control System and Audit Policy

    I.T. Security Policy Human Resource Policy

    Expenditure Policy

    Accounting & Disclosure Policy

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    BSD Circular 17 of 2008

    ICAAP supplements quantitative riskassessment in Pillar-1 of Basel II

    ICAAP is set of policies, methodologies,techniques, and procedures to assess the capitaladequacy requirements in relation to the banksrisk profile and effectiveness of its riskmanagement, control environment andstrategic planning

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    Elements of ICAAP

    Board and senior management oversight

    Sound capital assessment

    Comprehensive assessment of risks Monitoring and reporting

    Internal control review

    Core for every angle of Risk Management

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