Orm Notes
Orm Notes
Orm Notes
Operational risk can refer to both the risk in operating an organization and the
processes management uses when implementing, training, and enforcing
policies. Operational risk can be viewed as part of a chain reaction: overlooked
issues and control failures can— whether small or large — lead to greater risk
materialization, which may result in an organizational failure that can harm a
company’s bottom line and damage its reputation. While operational risk
management is considered a subset of enterprise risk management, it excludes
strategic, reputational, financial, and market risks, focusing on unsystematic risks.
Table: Loss Event Types and Examples Defined by the Basel Committee
How Operational Risk Management Works
When dealing with operational risk, the organization has to consider every aspect of its
objectives. Since operational risk is so pervasive, the goal is to reduce and control every risk
to an acceptable level. Operational Risk Management attempts to reduce risks through the
linear process of risk identification, risk assessment, measurement and mitigation,
monitoring, and reporting while determining who manages operational risk.
Risk Identification
Operational Risk Management begins with identifying what can go wrong. As a best practice,
a control framework should be used or developed to ensure completeness. Identifying risks
begins with scenario analysis — taking a look at the challenges facing the business and
pinpointing areas that could disrupt operations or pose another risk to the organization.
Risk Assessment
Once the risks are identified, the risks are assessed using an impact and likelihood scale, also
known as a Risk Assessment Matrix. At this stage, risks are categorized by type of risk and
level of risk.
People
The people category includes employees, customers, vendors, contractors, and other
stakeholders. Employee risk includes human error and intentional wrongdoing, such as in
cases of fraud. Risks include breach of policy, insufficient guidance, poor training, bad
decision-making, or fraudulent behavior. People can pose a risk to the organization even
externally, as social media is more and more likely to have an impact on business. Risks
associated with people can be especially sensitive and tricky, especially since people play a
role in every aspect of an organization’s operations. Fostering a healthy risk culture through
training and regular communication is key to managing this area of risk.
Technology
Technology risk from an operational standpoint includes hardware, software, privacy, and
security. Technology risk also spans the entire organization and affects the people category
described above. Hardware limitations can hinder productivity, especially when in a remote
work environment. Software too can reduce productivity when applications suffer an outage
or employees lack training. Software can also impact customers as they interact with your
organization. External threats exist as hackers attempt to steal information or hijack
networks. This can lead to leaked customer information and data privacy concerns.
As technology expands to play a larger role in all of our lives risks in this space become
increasingly significant and complex. If not included already, business continuity plans
should address risks related to technology failures and other disruptions.
Regulations
Risk for non-compliance to regulation exists in some form in nearly every organization. Some
industries are more highly regulated than others, but all regulations come down to
operationalizing internal controls. Over the past decade, the number and complexity of rules
have increased and the penalties have become more severe.
Understanding the sources of risk will help determine who manages operational risk.
Enterprise Risk Management and Operational Risk Management both address risks in the
same areas but from different perspectives. In an effort to consolidate these disciplines,
some organizations have implemented Integrated Risk Management or IRM. IRM addresses
risk from a cultural point of view. Depending on the objective of the particular risk practice,
the organization can implement technology with different parameters for teams like ERM
and ORM.
Transfer: Transferring shifts the risk to another organization. The two most common means
for transferring are outsourcing and insuring. When outsourcing, management cannot
completely transfer the responsibility for controlling risk. Insuring against the risk ultimately
transfers some of the financial impacts of the risk to the insurance company. A good
example of transferring risk occurs with cloud-based software companies. When a company
purchases cloud-based software, the contract usually includes a clause for data breach
insurance. The purchaser is ensuring the vendor can pay for damages in the event of a data
breach. At the same time, the vendor will also have their data center provide SOC reports
showing there are sufficient controls in place to minimize the likelihood of a data breach.
Avoid: Avoidance prevents the organization from entering into a risk-rich situation or
environment. For example, when choosing a vendor for a service, the organization could
choose to accept a vendor with a higher-priced bid if the lower-cost vendor does not have
adequate references.
Accept: Based on the comparison of the risk to the cost of control, management could
accept the risk and move forward with the risky choice. As an example, there is the risk an
employee will burn themselves if the company installs new coffee makers in the break room.
The benefit of employee satisfaction from new coffee makers outweighs the risk of an
employee accidentally burning themselves on a hot cup of coffee, so management accepts
the risk and installs the new appliance.
Mitigate: Mitigating risks involves implementing action plans and controls that reduce the
likelihood of the risk and/or the impact it would have if the risk were realized. For example,
if an organization allows employees to work from home, there is a risk of data leakage due
to the transmission of data across the public internet. To mitigate this risk, management
might implement a VPN service and have remote users access the business network through
VPN only. This would reduce the likelihood of data leakage, thereby mitigating the risk.
We’ve mentioned a few times that very few risks can be completely eliminated. Noting the
residual risk — the risk remaining after mitigation — is an equally important part of the risk
mitigation phase of ORM.
Most likely, your organization already has some controls in place to combat risks. It’s still
wise to review those controls on an annual basis (at minimum) and determine whether
additional controls are needed if there are gaps in the control, or if the control is sufficient to
address the risk and requires no changes.
Step 5: Monitoring
Since controls may be performed by people who make mistakes, or the environment could
change, controls should be monitored. Control monitoring involves testing the control for
appropriateness of design, and operating effectiveness. Any exceptions or issues should be
raised to management with action plans established.
Within the monitoring step in Operational Risk Management, some organizations, especially
in financial services, have adopted continuous monitoring or early warning systems built
around key risk indicators (KRIs). Key risk indicators are metrics used by organizations to
provide an early signal of increasing risk exposure in various areas of the enterprise. KRIs
designed around ratios monitored by business intelligence applications are how banks can
manage operational risk, but the concept can be applied across all industries. KRIs can be
designed to monitor nearly any potential risk and send a notification. As an example, a
company could design a key risk indicator around customer satisfaction scores. Falling
customer satisfaction scores could indicate customer service representatives are not being
trained or that the training is ineffective.
IMPORTANT QUESTIONS: