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Prasad Kodali
Prasad Kodali
Prasad Kodali
May y 2010
Agenda
Sets Operational Risk policies and procedures Creates standards for assessments Maintains systems and standards for loss data collection Calculate Capital Report to Board and management committees Manage regulatory communication
Manage day to day risk Report loss events Execute assessment programs (RCSA, SA etc. )
Measurement Philosophy
Model on basis of relevant, quantitative data where available and reliable Scenario Analysis (SA) data is used:
as a proxy for external data as a means of addressing insufficient loss data to introduce forward-looking elements into the model to assist in the management of Operational Risk
Conservative judgments are made according to the quality of the data (e.g.
maximum correlation calculated is used)
No overrides are made to model inputs No qualitative adjustments are made post Monte Carlo simulation Transparent and Easy to explain
Measurement Inputs
Internal Loss Data A direct input into the model Direct losses > $20k are used to model both the loss frequency and loss severity distributions. E t External l Loss L Data D t An indirect input into the model A key input to the Scenario Analysis process, it provides participants with potential OR exposures relevant to the Firm. Also used to determine correlations between risk types and benchmarking. y Scenario Analysis A direct input into the model Used to model the severity distribution. Allows prospective changes to the risk profile to be reflected in the AMA model. Addresses data paucity in the tail of some risk type yp severity y distributions. RCSAs An indirect input into the model Used to identify and assess inherent risk, residual risk, control performance and appropriateness of mitigating actions. RCSAs trigger and inform the Scenario Analysis process.
Measurement Methodology
Model Inputs Model Processes Model Outputs
Severity-SA2
Severity
Above process is performed for each unit of measure Capital is aggregated using a Gaussian copula A conservative estimate of correlation between Risk Event Categories is used based on empirical research Multiple model runs are executed in a structured process to reduce simulation variance
1The
BEICFs
weights of ILD and SA data are derived using a scorecard approach for each unit of measure Simulation found to be conservative and stable relative to fitted severity distributions for SA data.
2Empirical
Granularity: Individual scenario, risk event type Structure of estimates: synthetic point, percentiles, frequencies by severity buckets and probabilities by severity buckets
Effectiveness in capturing changes in risks by engaging Biz units Stability and sensitivity of capital to changes in estimates Ability to aggregate estimates Acknowledge and leverage the consensus based decision making culture of Morgan St l Stanley
Collection of frequency estimates by standardized severity bucket at the Risk Event type level for each business unit was chosen and implemented starting 2006 Q4
Assessment Process
RCSAs are refreshed every quarter for all business units ORD and BU work together g to validated existing g risks and identify y any y new risks Triggers for Scenario Analysis re-assessment:
Change in RCSA risks or scores External Events Change in Business environment SA scores are stale, meaning they have not been re-assessed for more than 6 quarters
Operational Risk Event Annual Frequency by Severity Bucket
1 2 3 4 5 6 Total Freq. Upper Bound
$20M - $50M 1 15
$50M - $100M 1 20
$100M - $250M 0 0
$250-$1B 0 0
$1B+ 0 0
3. The last step is to estimate the frequency within each severity bucket
$ 100,000,000
0.20
0.07
0.05
0.00
0.00
0.00
0.32
2.
Rank
Scenario
1 2 3 4
Theft of intellectual/physical property Theft of confidential information (both MS and client) Fraudulent trading (Misrepresentation by counterparty, Forgery))
3 2 1
Investment Banking
Wealth Management
Investment Management
Equities
Fixed Income
M&A
GCM
Core
MB/PE
Ex-Commodities
Note:
Commodities
Orange boxes represent lowest level of modeling unit as well as lowest level at which scenario analysis was held HR & BCM workshops k h are conducted d t d on th the fi firm wide id l level, l BCM/CS: Business Continuity Management and Corporate Services