Prasad Kodali

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Operational Risk Management and Measurement

May y 2010

Agenda

Operational Risk Roles Measurement Philosophy Model inputs Model Methodology

Assessment Evolution of Scenario Analysis Process Granularity of Scenario y Analysis

Client and Regulatory focus

Operational Risk Roles


Firm Operational Risk Department

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

Business Line Risk Management


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

Frequency of Internal Loss Data Frequency

Internal Loss Data (>20K)


Weight x1
Severity-ID

Monte Carlo Simulation

Aggregate Loss Distribution (ALD)

AMA Capital Economic Capital


Scenario Analysis (>$10MM) Business Judgment RCSA Internal Data External Data Audit/ SOX Weight (1-x)1

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

Management Focus Items

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

Assessment Evolution of Scenario Analysis


Various methodologies for collecting estimates were considered :

Granularity: Individual scenario, risk event type Structure of estimates: synthetic point, percentiles, frequencies by severity buckets and probabilities by severity buckets

Criteria used to evaluate these methods:


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

$10M - $20M # Events # Years Frequency q y 1 5

$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

Rank Scenarios with respect to potential severity of loss.

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

1. The first step is to


validate Scenarios that could lead to a large loss.

Assessment Scenario Analysis Granularity


Morgan Stanley y BCM/CS HR

Sales and Trading

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

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