The highly regulated nature of the industry demands that financial services players undertake additional measures for managing non-financial risks, ensuring compliance, and staying ahead on required audits. Associated adverse financial and customer impacts further necessitate the continuous monitoring of critical risks. A key strategy to obtain a better picture of underlying risks is the creation and implementation of robust risk metrics or Key Risk Indicators (KRIs) that help with the early detection and mitigation of potential incidents.
Developing relevant risk indicators is a complex and multi-phased process that involves selecting meaningful metrics, ensuring data accuracy, aligning with regulatory and business guidelines, and adapting to the changing environment. Below are some of the major challenges faced by organizations in the financial services space around effective implementation of KRIs.
Inadequate risk management framework. Lack of a comprehensive risk management framework can result in unstructured governance without well-defined roles and responsibilities and inconsistent metric definitions and reporting formats.
Fragmented metrics. Business functions across the organization adopt a different approach to creating and implementing metrics to understand risk levels. In addition, different tools, applications, and infrastructure can generate metrics which are not standardized to provide a holistic enterprise level risk view.
Siloed data. Risk metric data is often siloed across different business functions and systems with limited traceability and documentation. As a result, it impacts the potential for performing analysis and derive insights making it difficult to identify and remediate risks in time.
Benefits of Enterprise-wide Risk Reporting
Adopting an enterprise/LOB level approach and developing the right metrics aligned with defined risks and controls, organizations can drastically improve overall risk management through proactive detection and prioritizing the mitigation of the following critical items:
- Regulatory compliance – risk measurement provides clear insight into level of adherence to regulatory guidelines and existing gaps to achieve required compliance.
- Early risk warnings – periodic risk monitoring through metrics helps organizations understand potential vulnerabilities and take corrective actions in time.
- Data-driven decision-making – KRIs provide quantifiable insights into risk exposure and associated urgency, supporting Executives in making informed strategic decisions.
- Improved resource allocation – high-severity risk areas are identified enabling appropriate allocation of people, time, and investment to tackle immediate priorities.
- Enhanced business resilience – metrics improve organization’s readiness to adapt to changing environments and support operational continuity by identifying risk areas early.
- Risk-aware culture – strong risk metric program enables leadership and employees to integrate risk management into day-to-day operational activities, fostering increased accountability.
Current Approaches to Risk Monitoring
In response to the rising emphasis on risk reporting, financial institutions across the industry have adopted various approaches to risk monitoring. Based on our experience and analysis of risk management across multiple organizations, these strategies are guided by the level of maturity of risk and control frameworks which in turn depends predominantly on their size, complexity of their risks, and leadership focus.
Table 1: Maturity of Risk Reporting Across an Organization
Creating an Optimal Risk Governance Model
Regardless of a firm’s risk profile, governance models are constantly being enhanced to meet regulatory expectations, more pronounced in the financial services space. In addition, stakeholder needs for greater clarity and transparency of risk reporting requires structured processes with defined ownership at every stage of risk reporting lifecycle.
Below, we set out some of the main areas of focus when establishing strong governance in place for risk monitoring.
Policies and standards. Evolving requirements and complexities in regulations are driving financial services firms to improve their processes for better policy management and ensuring that the interlocks across risk frameworks and standards are in place.
Controls. Effective controls help define KRIs by guiding the identification of measurable components. Metrics need to be aligned with control objectives to help measure their efficacy as well as establish a feedback loop for continuous improvement.
Roles and Responsibilities. Robust governance structure should start with defining the right teams and accountable owners (SMEs, Risk, Audit, etc.) to ensure appropriate level of scrutiny around data quality, metric applicability, and audit readiness.
MIS and Reporting. Real-time access to retrievable information allows Leadership to review and if needed, take corrective action in time. Completeness of reporting that includes risk coverage and associated compliance helps teams proactively assess the situation and implement remedial measures.
Risk Taxonomy. Classification of risks, if not adopted uniformly, can lead to inconsistent categorization of limiting transparency and clarity of where risk is occurring. Connecting the risk drivers across businesses help define the taxonomy and allow for targeted remediation based on risk source.
With these focus areas front of mind, the following can be viewed as key components of effective risk reporting:
Organizational Alignment
- Governance – an operating model focused on risk with robust governance components and processes acts as a blueprint for understanding risk reporting requirements and drives the design of overall KRI program
- Change management – in addition to robust governance, establishing a strong change management model helps ensure any modifications to metric definition, logic, ownership, or data source are properly documented and governed
Cyber Security Alignment
- Firms should align reporting with their organization's cyber security objectives as it represents a major area of potential risks and business exposure. The goal should be to ensure that reporting can effectively monitor and help thwart security challenges and emerging threats that can significantly impact the business.
Regulatory Awareness
- Evolving requirements for regulatory transparency in the financial services industry drives the need for enhancing reporting ensure there is compliance and enable remediation before possible violations
- Regulatory readiness assessment should be an ongoing process that is continuously improved based on feedback and insights from the reporting data. This includes identifying areas for improvement and implementing changes to the reporting processes.
Holistic Risk View
- Once risks are understood and the foundations for collecting data have been established, metrics and their distribution should be developed to align with the severity of risks across each business function
- The potential impact and severity of risks varies across organizational capabilities drives the volume and distribution of KRIs.
Proactive Remediation
- Metric breaches should be analyzed and guidelines should be established to understand potential gaps in processes and risk management; some of the key insights coming from well-defined risk metrics should include
- Analysis of metric values especially around breaches
- Overall trend to highlight areas where better risk management is required
- Detailed resolution plan and ETA for bringing status back to ‘Green’
- Enhanced processes and stronger controls can help close the gaps; metric should be monitored in upcoming reporting cycles with enhancements in place to update KRIs with changing business requirements and risk profile.
Conclusion
Developing effective risk monitoring programs through metrics can be overwhelming and effort intensive. Expertise in financial services industry best practices, objective and independent perspectives, and advanced data and technology related support can go a long way to ensure proper integration of business needs with your enterprise risk management frameworks.
Capco has extensive experience across Risk, Data, and Technology in the context of financial services and we are well-positioned to help develop and implement a robust risk monitoring and KRI program. Below are some of the activities we can help you with:
- Enhancing risk management governance
- Assessing and enhancing risk reporting
- Optimizing monitoring and reporting processes
- Designing and implementing Key Risk Indicators
- Assessing regulatory readiness and response
- Overall data governance.