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Climate Change Risk Management in Banks The Next Paradigm Issn 1St Edition Saloni P Ramakrishna Online Ebook Texxtbook Full Chapter PDF
Climate Change Risk Management in Banks The Next Paradigm Issn 1St Edition Saloni P Ramakrishna Online Ebook Texxtbook Full Chapter PDF
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Saloni P. Ramakrishna
Climate Change Risk Management in Banks
The Moorad Choudhry Global
Banking Series
Series Editor
Moorad Choudhry
Saloni P. Ramakrishna
Climate Change
Risk Management
in Banks
The Next Paradigm
The views, thoughts and opinions expressed in this book represent those of the author in her individual
private capacities, and should not in any way be attributed to any employing institution, or to the author
as director, representative, officer, or employee of any affiliated institution. While every attempt is made
to ensure accuracy, the author or the publisher will not accept any liability for any errors or omissions
herein. This book does not constitute investment advice and its contents should not be construed as such.
Any opinion expressed does not constitute a recommendation for action to any reader. The contents
should not be considered as a recommendation to deal in any financial market or instrument and the
author, the publisher, the editor, any named entity, affiliated body or academic institution will not accept
liability for the impact of any actions arising from a reading of any material in this book.
Most of the references and quotes are from publicly available sources. Thanks to the regulators and
global organizations, these documents can be accessed free of charge from their respective websites.
Given that climate change risk is an evolving discipline, since publication different FAQs and clarifications
would have been and will be published. For updated information please check the official websites of the
referred content. For ease of reference the year of publication of each document referred has been given
in the Bibliography.
ISBN 978-3-11-075791-0
e-ISBN (PDF) 978-3-11-075795-8
e-ISBN (EPUB) 978-3-11-075797-2
ISSN 2627-8847
www.degruyter.com
Advance Praise for Climate Change Risk Management
in Banks: The Next Paradigm
Ms. Saloni Ramakrishna has a long and deep experience in supporting financial institu-
tions to enhance and adapt their risk management to rapidly changing external envi-
ronments. With this background, she is well-positioned to write about the practitioner’s
guide on designing, developing, and implementing the practical methodology of cli-
mate-related risk management. Through her book, Climate Change Risk Management in
Banks: The Next Paradigm she has shared with us the essential framework required for
establishing a proper climate-related risk management function. I believe her work will
be a milestone in the literature on banks’ climate-related risk management.
Tsuyoshi Oyama, Author; CEO, RAF Laboratory Co. Ltd.; earlier Partner, Deloitte
Touche Tahmatsue; and Former Director-General of the Financial System and Bank
Examination Department, Bank of Japan
Ms. Saloni Ramakrishna, an acknowledged finance and risk professional, in her inimita-
ble style, explores the various aspects of climate change risk that banks face and its risk
management in a strikingly lucid manner. The book, Climate Change Risk Management
in Banks: The Next Paradigm, with the body of work it encapsulates, is a worthy addi-
tion to the literature of the emerging discipline of climate-related financial risk manage-
ment. A special mention needs to be made of the extra mile she goes to detail the
different building blocks that will create a robust foundation and scalable framework
for managing climate change risk. With this, she has moved the climate risk manage-
ment dialogue beyond financial rhetoric to an actionable business proposition.
Marc Irubétagoyena, Director of BNP Paribas; Global Head of Stress Testing
and Financial Synthesis and Group Risk Board executive
With her extensive and real-world experience as a financial services industry practi-
tioner in the risk and data management space, Ms. Saloni Ramakrishna covers the
various aspects of climate-related financial risks in her signature style of simple and
straightforward narrative. The book, Climate Change Risk Management in Banks: The
Next Paradigm, is a unique combination of real world challenges, concepts and a practi-
cal framework rolled into one. Possible ways of managing this new risk universe are cov-
ered in a succinct yet comprehensive manner. A shout-out for her focus on “the complex
universe of interlinks,” which is where most of the industry’s challenges will be.
Sridhar Aiyangar, Group Head, Balance Sheet and Liquidity Management, Bank ABC
In the book, Climate Change Risk Management in Banks: The Next Paradigm, Ms. Sal-
oni Ramakrishna, with her practitioner’s wisdom and industry experience, opens the
book with an overview of risk and the flavors of risk that banks deal with. As she so
rightly points out, at a fundamental level, all financial risks have a common set of
https://doi.org/10.1515/9783110757958-202
VI Advance Praise for Climate Change Risk Management in Banks: The Next Paradigm
principles. Having laid that foundation, she goes on to fluently discuss practical han-
dling of climate-related financial risks, a nuanced and complex subject. She brings
great value to this critical but young and evolving subject through a rare blend of cu-
rated content and strategic intent with real world issues and a practical approach.
Dr. Sankarshan Basu, Author; Dean of AMSOM; Professor,
Indian Institute of Management, Bangalore; Ph.D. from and taught at the London
School of Economics and Political Science (LSE)
Through her book, Climate Change Risk Management in Banks: The Next Paradigm, Ms.
Saloni Ramakrishna brings to bear her vast hands-on practitioner’s experience of advis-
ing and implementing projects for global clients, on how technology weaved intrinsically
into complex risk management frameworks is a huge value multiplier. Her emphasis on
the role and relevance of a well thought out, appropriately designed “Climate Informa-
tion Architecture” as the bedrock of creating and perpetuating an active climate change
risk management program, is spot on.
Jason Wynne, Group Vice President, Oracle Financial Services Global Business Unit;
Previously Risk Technology Head of Australia & New Zealand Banking Group Limited,
Australia
To my mother,
Pisipati Suguna Murthi
The indomitable spirit, who taught me the essence of “joie de vivre” by living it
every day of her life.
Acknowledgments
Men argue. Nature acts. –Voltaire
The greatest benefit of authoring a book is the immense learning it affords the author.
The journey of authoring this book has taken me through a rich canvas of myriad
sources and experiences. From researching industry challenges and practices, to pe-
rusing content from authentic sources – regulators and global organizations that are
shaping the narrative, exploring operational constructs across the life cycle of climate
change risk and its management used by successful practitioners as well as drawing
from my real-world experiences. All together this has been one of the most significant
kaleidoscopic journey. I have many to thank for insights gained and the intricacies
understood.
My foremost gratitude is to “Mother Nature.” This book is one of the ways I am
paying homage to climate and environment with an acknowledgment of the enormity
of responsibility placed on each of us to preserve nature, so it can continue to protect
and nurture humanity.
A big shout out and thank you to my partner Ramakrishna Gullapalli, my rock, my
strength, who made this book possible, in every conceivable way. Gratitude to my fa-
ther, Sh. Pisipati Sri Ramachandra Murthi, my guru; my mother, Pisipati Suguna Mur-
thi, to whom this book is dedicated; and Sameer Kumar Pisipati, my elder brother. Bless
Sravani, the inexhaustible fountain of energy, Srikar, the boundless powerhouse, Sud-
hir the epicenter of positivity and all the young ones of the family, my collective source
of joy and creativity. Thanks are due to Seetha, for being there always!!
This book happened because of Professor Moorad Choudhary, a prolific author.
Our common ground is our passion for the banking industry. It was his suggestion that
I author a book for the Global Banking series which he is the editor of. His infectious
enthusiasm is the genesis of this journey. Thank you, Professor, for motivating me to
embark on this arduous but fulfilling path.
Senior practitioners and thought leaders, Dr. Sankarshan Basu, Professor Moorad
Choudhary, Tsuyoshi Oyama, Marc Irubétagoyena and Sridhar Aiyangar, have readily
agreed to bring to bear their distilled wisdom and hands on experiences to add to the
industry narrative of the budding climate change risk discipline, through their “Prac-
titioner’s Notes,” which prefix the five parts of the book. These notes have enriched
its content manifold. A big thank you to each of them for their positive collaboration.
A special note of appreciation and thanks to the regulators and global organizations
who are working through the multilayered and multithreaded complex universe of cli-
mate change and its risk management, sharing their guidance and best practices, as
they navigate through the gigantic standardization exercises. It is from this well thought
out and well laid out landscape of material that I have drawn nuggets to string together
concise, consumable curated content. Thanks is also due to them for readily and gra-
https://doi.org/10.1515/9783110757958-203
X Acknowledgments
ciously permitting usage of their references, perspectives, definitions and nuances that
will shape the tone, timber, and direction of the young but challenging discipline.
My understanding of the deep, involved, and interlinked climate change risk man-
agement has been enriched manifold through the many discussions on the discipline
with banking professionals, regulators, consultants, IT professionals, financial services
industry association members and many other stakeholders, who have all added to my
learning canvas with their unique perspectives. Thanks to each one of them.
With great joy, I place on record my acknowledgment of the creative, facilitative
ethos and environment my organization, Oracle Financial Services and my colleagues
provide, that promotes a spirit of excellence.
My thanks to publishers De Gruyter, with a special call out to Stefan Giesen, the
perfect gentleman, because of whom the proposal experience was so positive. Thanks is
due to Jaya Dalal, the editor, whose serenity, I marvel at. Thanks to the entire editorial
team of De Gruyter.
Many thanks to all of you, dear readers, and fellow professionals, for being part of
this journey.
Saloni P. Ramakrishna
Preface
Water water everywhere – Nor any drop to drink. –Samuel Taylor Coleridge, The Rime of Ancient
Mariner
In hindsight, it seems that the great poet S.T. Coleridge, almost two centuries ago, tried
to warn us about the impending climatic catastrophe if we did not steer the mythical
“ship” to safety!! The reality today is that, while two-thirds of the earth is covered by
water, only 3% of it is drinkable with that percentage fast depleting. Water stress and
water crisis are only two facets of the fallout of casual and irresponsible handling of
climate related issues. The broader landscape across various aspects of everyday life,
that could be impacted negatively, due to adverse climate change, is immense.
No one can remain impervious to the risks humanity faces if urgent remedial steps
are not taken to protect the environment in its current fragile state. As a citizen of the
world, I am deeply connected to and concerned with all aspects of climate change.
When I thought of penning my next book, “climate and its risk management” was natu-
rally the theme I chose.
There were two challenges to execute this thought. One, the scope of the subject
of ESG1 and sustainability finance, both in terms of width and depth is too vast to en-
capsulate in one book, even if it is focused on one sector, the financial services. The
second, as a published author2 in risk management space, I have experienced firsthand
the focus, clarity and rigor required to take a foundational yet comprehensive approach
that stakeholders can relate to and use as a guidepost. Acknowledgement of these chal-
lenges led to the two definitional themes that shaped the scope of the book. The focus
on climate change, and its risk management in banks.
The canvas and the contours of the landscape created in this book are an amal-
gamation of real world experience, across the globe, of working with data, risk and
finance functions of financial services firms both as a banker myself as well as a con-
sultant. An experience that is continuously enriched through conversations, experien-
ces gained and shared with global organizations by working on the ground issues
with Industry Leaders.
As a practitioner in the financial services industry, I can visualize the crucial role
banks can play in positively influencing the climate change risk management narrative
while ensuring strong and sustainable growth for themselves. The combination of un-
derstanding the urgency of taking action in climate change risk management and my
field of experience in execution of complex projects in data and risk management has
led to the genesis of this book. The decision and its follow through have taken me on an
invaluable learning and sharing journey that is encapsulated in the following pages.
https://doi.org/10.1515/9783110757958-204
XII Preface
Adding depth and practical hands-on wisdom, five industry practitioners, each an
acknowledged expert in their area of operations, and working on climate change risk
management in their distinct way, have contributed to the content and narration
through the “Practitioner’s Notes,” a unique feature of this book. These notes prefix
each of the five parts.
The book is aimed at all the stakeholders of the financial services, particularly the
banking industry – practicing bankers, banking associations, regulators, consultants,
system integrators and analysts. It will be of use to educational institutions that have
financial services and/or risk management and climate change in their curriculum. It
will also be relevant to other players like banking colleges, risk management associa-
tions, and banking associations/industry bodies as for all others who are interested in
understanding the role and impact of financial services firms on climate risk and vice
versa, like governments and their policy makers as well as world organizations. Writ-
ten in simple text, it is aimed at creating the much-needed literary asset for both the
stakeholders of the financial services industry as well as academia.
Climate change risk management in banks as a distinct discipline is in a very na-
scent stage. The impact of adverse changes of climate on the socioeconomic canvas
has been and is debated fiercely. However, the potential sizeable negative effect on
the financial services industry itself and the need for a possible organized method to
counter it, both for its own well-being and for the environment at large, is little under-
stood, much less documented. This book centers on these critical aspects.
The varied facets of climate risk management right from risk sources all the way
to regulatory approach are the focus of this work. It presents, in simple articulate
style, an orderly and systematic approach. The attempt is to separate “the wheat from
the chaff,” and reduce the surround noise so the fundamentals are understood and
focused on for positive action. It encapsulates curated content, as relevant to climate
change risk, from regulators and global organizations. This knowledge not only pro-
tects businesses from negative impacts but also give the much-needed competitive ad-
vantage that goes a long way in value creation, preservation, and growth.
Saloni P. Ramakrishna
Design and Structure of the Book
The secret of getting ahead is getting started –Mark Twain
This book presents a possible path to managing “climate change risk” effectively so it is
handled holistically. Multiple aspects of the subject and their interlinks are delved into
including the connections with other risk areas. The text offers varied and detailed in-
sights into specific risk aspects of vital importance to bankers through an operational
framework which will give the industry the much-needed edge in understanding and
managing it.
The book is presented in five parts, prefixed by “Opening Notes,” and suffixed by
“Closing Notes.” Each part, prefixed by a “Practitioner’s Note,” has a brief abstract of
the themes covered in the chapters within it.
Part 1 – Context setting: Brief overview of risk management – The first part provides a
bird’s eye view of “risk” and its management in financial services. Content here is re-
ferred to in subsequent sections to compare and contrast with climate change risks.
Part 2 – The what, why and who of climate-related financial risks – This part sets out
the core aspects and looks at the impact of adverse climate changes, its primary risk
drivers, transmission channels, amplifiers and related themes.
Part 3 – The how part – This part seeks to provide the building blocks and a functional
toolkit for navigating the climate risk universe providing an operational and action-
able framework. This part highlights the critical components and functional con-
structs required for creating an effective climate change risk management structure
in banks.
https://doi.org/10.1515/9783110757958-205
XIV Design and Structure of the Book
Part 5 – Going forward – In this part, the stated roadmaps of regulators, important
global organizations such as TCFD, NGFS, ISSB, etc. and banks are looked at briefly.
Each of these, both individually, and in combination, will shape the narrative going
forward.
The Closing Notes section encapsulates my views on what could help shape this young
subject to its potential of being able to build and sustain a healthy future not just for
banks and the economy but also the larger ecosystem.
Opening Notes
The best time to plant a tree was 20 years ago. The second-best time is today. –Chinese Proverb
I always wondered (and still do) if “climate risk” is a misnomer – shouldn’t it be “Eco-
system @ Risk”!! Unless some constructive and urgent action is taken to address, re-
duce and rectify the negative impact from all of us individually and collectively,
inclusive of all organizations, there would be enormous financial and economic fall-
out, not to mention the irreparable loss to humanity. If there is a subject that has cap-
tured attention across the globe, it is climate change. The pandemic was like a
wakeup call to shake us awake from our slow-paced response to something that is
and should be an immediate concern. Fact is, managing climate change positively is
central to a “sustainable future” for ALL.
The economy, climate and environment are deeply interlinked – each affects the
other in many ways. A quick example to illustrate the interlink between environment,
global economy and climate change is a data point from Bank of England that I came
across -The floods in Thailand in 2011 resulted in over $45 billion of economic losses.
More positively, at the other side of the globe, the mangrove forests in Mexico provide
storm protection and give support for fisheries and eco-tourism. These benefits have
been estimated at $70 billion in financial terms. These numbers, one in a multitude of
such data points, set the context for the financial implications of both sides of the
coin – inaction and action.
Climate risk, while deeply linked to the wider conversations on climate change, is
a distinct and critical subset of the broader umbrella themes of climate change and
environment. The larger discussions are shaped by global dialogue and intergovern-
mental summits, considering diverse aspects both of mitigation and adaptation strate-
gies. The understanding and analysis of climate risk, on the other hand, is shaped
largely by financial regulators and global organizations like TCFD, NGFS, ISSB, GHGP,
PCAF and other related private sector institutions. Understanding the impact of physi-
cal and transition hazards/drivers, exposures and vulnerabilities, and how they im-
pact individuals, households, corporates, financial institutions that lend and invest in
them, their financial outcomes, impacting different sectors, geographies and individu-
als differently, is the focus of the risk lens.
This book looks at climate change risk management from the lens of financial Serv-
ices firms in general and banks in particular. It covers themes like relevance of cli-
mate change risk to banks, its impact and how to manage it in a way that it can create
a win-win situation for all stakeholders including the environment and society. The
many dimensions and nuances added due to the exponential increase in the complex-
ity of the financial world on one side, and the possible catastrophic impact of adverse
climate changes on economies on the other, have brought the need for serious dia-
logue and documentation on “climate change risk management” to center-stage.
https://doi.org/10.1515/9783110757958-206
XVI Opening Notes
Dubbed as the next big thing and the new frontier in the risk management world
for banks, no risk area has been as challenging and hazy as managing climate risk, a
subject that demands to be treated as a focused discipline. The challenge stems from
the fact that it is an evolving, layered, intricate, interconnected and nuanced canvas.
The ability to see it in its totality for capturing its essence and at the same time to be
able to zero in on the relevant specifics of the scope to create an actionable frame-
work is an art, craft, and science, all rolled into one.
As an Industry practitioner with hands-on experience for over three decades in
risk and finance space from “all sides of the table” of financial services industry, I have
learnt that the best way to manage risk is through a structured proactive approach.
The narrative and presentation of the book is simple, straight forward and struc-
tured by design. As I acknowledge in my books, the narration style is influenced by
guiding principles ingrained in me by my father and my mentors.
– “To understand or explain a subject, look for answers to 3 ‘W’s, the What, the
Why and the Who, that will give you the rationale, context, and the impact. The
‘H’, the How part, provides answers to establishing a practical set of doable con-
structs that provides answers to the required approach, framework, sequence
etc.” This insight from my father stands me in good stead both as a professional
and as an author.
– The art of narration is its simplicity and straight forwardness – because “all funda-
mentals are simple and straightforward and do not need the garb of jargon to claim
their rightful place” – a profound sense of wisdom one of my mentors instilled in
me. The narration, therefore, is simple and straight forward, de-jargonizing and de-
mystifying the subject (to the extent possible), presenting it in a consumable, action-
able and “to the point” form.
– The primary objective of literature is to “elevate the debate, energize the dia-
logue, and go from what it is to what it can be. That is how growth and progress
happen.” This was the dictum of another one of my mentors. The effort is, there-
fore, to elevate the current tactical context of climate risk to its rightful strategic
ability of becoming a powerful competitive weapon for organizations, enhancing
the overall wellbeing of the system and aid in creating a sustainable future.
The objective is to rise from accepting to actioning in the real world. The goal of regu-
lators and organizations is a systemic and systematic integration of climate risk man-
agement into the business and strategic fabric of the organization. Being a young and
evolving discipline, the rule book on climate risk management, if anything, is and will
be an iterative process for some time to come, but a well thought out foundation will
go a long way in optimizing capital, costs, time, and human resources while trying to
arrest further deterioration of the climate. All stakeholders, right from regulators to
the risk managers at their desks in individual firms are learning along the way. This
book adds to shaping that budding narrative.
Contents
Acknowledgments IX
Preface XI
Opening Notes XV
Chapter 1
An Overview of Risk and Risk Management in Banks 9
Chapter 2
The Different Flavors of Risk that Banks Work With 18
Chapter 3
ESG and Climate Change as Relevant for Banks 35
Chapter 4
Climate-related Financial Risks for Banks 42
Chapter 5
Importance of Understanding and Acting on Climate Change 58
Chapter 6
Challenges for Banks in the Climate Change Risk Management Space 62
Chapter 7
Players of the Climate Change Risk Landscape 67
XVIII Contents
Chapter 8
Building Blocks – The Big Picture 87
Chapter 9
Principles for Effective Management of Climate-related Financial Risks 91
Chapter 10
Risk Appetite Statement (RAS) 96
Chapter 11
Climate-related Risk Data 105
Chapter 12
Identification, Assessment and Measurement of Climate-related Financial
Risks 117
Chapter 13
Scenario Analysis and Stress Testing 150
Chapter 14
Risk Mitigation, Control, and Monitoring Process 176
Chapter 15
Disclosures and Reporting Requirements 189
Chapter 16
Operating Model for Climate Change Risk Management at Banks: Some
Pointers 208
Chapter 17
Interlinks – The Big Picture 225
Contents XIX
Chapter 18
Interlinks with Financial and Non-financial Risks of Banks 231
Chapter 19
Capital and Climate Change Risks – the Links 244
Chapter 20
Going Forward 257
Bibliography 281
Index 299
Part 1: Brief Overview of Risk Management
The Big Picture
A business without risk is a risky business.
Banking is like any other business in many ways and yet distinctly different from
others. It has the same sustainability, growth, and profitability objectives. Where it dif-
fers is in its role as a core vehicle of the economic activity of its ecosystem, due to its
part in financial intermediation. That role is central to how all stakeholders view, inter-
act, and define boundaries to banks and other financial industry firms which are some
of the most regulated industries, given their critical role in the economic landscape of
not only countries and regions, but also the entire globe in this connected universe.
In the response to climate changes, there is a dual expectation from the financial
services firms. On the one hand to reduce significantly their contribution to the ero-
sion of the climate, and on the other to help their customers transit to more sustain-
able operations. All this is expected while ensuring that their business sustains and
grows, hedging the financial risks that are posed by adverse climatic changes. Written
through the lens of banking, the focus of this book is to explore “climate change risk
management of banks.” It is important to set the context to that conversation, to get a
foundational insight as well as appreciation of “risk” and its management frameworks
in banks.
This introductory part sets out the bird’s eye view of risk and its canvas as well as
its management fundamentals. Risk is an inherent part of every business, geography,
and by extension every enterprise. It presents both threat and opportunity. Accep-
tance of risk, its outcomes/costs, and planning out the optimal approach to manage it
for the benefit of the enterprise is the goal. Risk management is the process of objec-
tively identifying the potential of both downside and upside of business transactions,
optimizing the upside while monitoring and mitigating the downside. Enterprises
take calculated risks to optimize returns by making it an ally, as risk taking is core to
value creation.
Risk as a concept is simple and complex at the same time. Understanding “risk” at
its core is simple – it is the contextual nuances that add the layers of complexity. Risk
has always been associated with “the possibility of loss,” the downside. The loss itself
could be any of the following – financial, physical, or reputational, each with dire con-
sequences. Rarely, if at all, is the “upside” of risk spoken of. This is not surprising
given that the usage and association of the term has almost always been in the context
of negative impacts.
However, ignoring the possibility of a positive outcome is blindsided, because this
negates the very essence of calculated risk-taking for value creation. Yet one does not
hear a CXO say that the organization stands the risk of making “gains.” But a good
risk management system needs to be designed to give a view of the potential both
ways (downside and upside). Risk presents a mixture of a potential significant down-
https://doi.org/10.1515/9783110757958-001
4 Part 1: Brief Overview of Risk Management
side and/or a potential of upside. There lies the complexity of grasping the concept
and its nuances.
Understanding and planning for the upcoming diaspora of risks to “ride the
wave” to create value for the firm is the focus of businesses. The problem is that not
all risks and all impacts can be visualized and planned upfront. The coronavirus pan-
demic of 2019 forward is a case in pointer. There will be surprises, some nasty ones. It
is at these times that the resilience of the organization and its risk management is put
to the test. Geopolitical risks, natural disasters, and sustainability initiatives will make
new and challenging demands on banks. The bottom line is that risks are dynamic in
nature and their management needs to be planned as such with built-in flexibility.
Risk stems from different sources having different outcomes. This is evaluated
and approached as banks manage different flavors of risk like, credit, market, liquid-
ity, operational, and reputational risk, to name a few material categories. While each
of these require their specialized evaluation, controls, and action, the fact remains
that there is no “standalone” risk – each of them is intertwined and impact one an-
other. As an example, pandemic risk (the new kid on the block), which some banks
have categorized as strategic risk, dotted its link not only to credit risk, owing to the
potential of default or delayed repayments, but also to cybersecurity risks (technology
risks), as digitization and remote working were becoming the norm.
Two other themes need a mention here. The first is capital and related buffers
that banks hold, which in principle, is both the shareholder’s stake (shareholder’s
skin in the game) and also the cushion to take the blow from losses. The other aspect
of importance is the return both on equity and investment because banking, like
what was said earlier, is a business with sustainable growth objectives. Therefore, it
is critical to have a healthy risk-return relationship. The ability to price risk correctly
is critical for sustainable growth of banks. However, the multiple low-cost options for
various services brought to the fore by digitization, technology, and fintechs in the
financial services industry has resulted in lowering costs for customers but increasing
the risks for banks. This has also resulted in challenging the ability of banks to price
risks realistically. Banks, therefore, need to have a proactive risk pricing and manage-
ment capability and a speedier response to market opportunities. All of these become
more complex and pronounced in the climate change risk space, which will be ex-
plored through the different sections of the book.
Practitioner’s Note Core Risk Management Fundamentals are Common Across Risk Classes 5
Practitioner’s Note
Core Risk Management Fundamentals are
Common Across Risk Classes
Dr. Sankarshan Basu
Risk in the strict sense of the word is defined as “the effect of uncertainty in outcomes
of an event.” If the outcome of all events were always certain and known there would
be no risk element at all. It is due to the fact that there is intrinsic uncertainty in the
outcome that leads to the existence of risk. In that sense, risk is inherent in every facet
of life, of both individuals and organizations. As Walter Wriston, the former chairman
of Citicorp had put it: “All of life is management of risk, not its elimination.”
The field of risk management is synonymous to “decision making” and forms a
part of the disciplines of statistics, operations research, economics, finance, psychol-
ogy as well as management. Exposure to risk is a given. The effort is to try and man-
age the risk so that it stays “in control.” The skill is to try and manage it effectively.
For banks, risk management is at the core of their business.
Banks can be classified into one of three groups in terms of their risk taking (risk
bearing) ability:
a. Risk Averse: This is the set of organizations that do not want to take any risk on
themselves and at all times try to minimize the risk that they bear. In practice,
existence of such organizations is difficult. More so if they want to be a going and
growing firm.
b. Risk Neutral: This group is indifferent to the risk that they bear – they do not
make any extra efforts to either reduce or increase the risk that they bear. This
stance is not possible for commercial banks.
c. Risk Seeker: This category seeks to take on and actively manage risks. They be-
lieve in the adage “High Risk, High Returns” and want to take on risk in pursuit of
higher returns. Banks, as vehicles of economy, while typically avoiding uncontrol-
lable risks, would like to ride the tide of manageable risks to optimize returns. In
that context banks are seekers of “feasible” risks.
Risk management in the financial context is the fact that an unexpected negative out-
come leads to a financial loss and the entire concept of financial risk management
and by extension a bank’s risk management is based on how to measure the expected
financial loss and manage that level of loss.
Given the fact that risk will exist and is an integral part of organizations, the phi-
losophy of risk management lies in the three principles of:
1. Identification of the sources or causes of risk.
2. Accurate measurement of the risks to which one is exposed to.
6 Part 1: Brief Overview of Risk Management
3. Trying and controlling the risk to the extent feasible and possible such that the
risk is within the ability to bear it.
Ms. Saloni Ramakrishna expertly and succinctly reiterates these principles in this
book, bringing to fore the foundational reality that risk and value are two sides of the
same coin, provided they are identified, measured and managed well.
Risk in general can be classified into two categories: business risk and non-
business risk. Business risks can be described as those type of risks which the organ-
izations willingly and knowingly undertake with the intention of creating increased
competitive advantage and value for all the stakeholders. These are risks which could
be attempted to be minimized by the organization by proper decision making, good
controls, and can be treated as a core competency of the business enterprise.
For banks, the business risks take on different flavors of risks which are clubbed
into two broad categories: financial and non-financial risks. The former encompasses
the traditional risk categories of credit, market, liquidity and operational risks and
the non-financial risks broadly cover legal, reputational, regulatory, and strategic
risks. Though, as Ms. Saloni Ramakrishna, a financial services practitioner of repute,
so aptly points out, there is nothing like non-financial risk in the medium to long
term, from an impact on balance sheet perspective. The classification is more on the
objective measurability of these risks as well as the timing of impact.
Non-business risks on the other hand are those risks that are external to the orga-
nization but it is nonetheless exposed to. For example, risks resulting from fundamen-
tal shifts in the economy, political environment or events could be treated as these
kinds of risk. Organizations rarely have any control over these types of risks and they
are very difficult to manage. Only a marginal benefit may be obtained by diversifica-
tion, though not in all situations. Climate change risks fall into this bucket. Ms. Saloni
Ramakrishna, in a simple and relatable way, brings to fore the complexity of climate
change risks, which stem from uncertain climate paths, influencing and influenced by
real economy, policy decisions and impact the financials of banks.
As a practitioner of risk management, I have seen that across time, while differ-
ent risk classes have been segregated to bring focus on the nuances of that specific
risk class, the fundamentals of risk, risk management and risk optimization are and
will remain the same. Manageable risk-taking for sustainable growth is a must. Realis-
tic risk identification, objective risk measurement (to the extent possible and feasible)
and effective as well as implementable controls are what differentiates successful or-
ganizations from the non-successful ones. Climate change risks too, will need these
foundational aspects woven into banks’ enterprise risk frameworks as they under-
stand and incorporate climate-related nuances to that framework.
Practitioner’s Note Core Risk Management Fundamentals are Common Across Risk Classes 7
Dr. Sankarshan Basu, an alumni of IIT Kharagpur and London School of Economics and Political Science
(LSE), UK, is a Dean at Amrut Mody School of Management, Ahmedabad University, and has been a profes-
sor of Finance and Accounting at the Indian Institute of Management Bangalore (IIM Bangalore). Dr. Basu
a published author, an educator of repute and has been a teaching faculty at London School of Economics
and Political Science, Heriot Watt University, Edinburgh, U.K. and a Visiting Professor at University of
Twente, Netherlands, Gothenburg University, Sweden, ESCP, Paris, CFVG, Ho Chi Min City and Hanoi, Viet-
nam and Asian Institute of Technology, Bangkok. He is an acknowledged authority on risk management
and is a member of many risk management committees.
8 Part 1: Brief Overview of Risk Management
Section Abstract
The two chapters in this part explore the core and nuances of the “risk,” its different
flavors and its management, particularly in the context of banks. The objective is to
lay out only the important foundational aspects which can then be compared and con-
trasted with climate change risk. As understanding of the financial impact of climate
change starts to take center stage with sustainability, resilience, and organizational
agility demanding attention; first an understanding and then a refresh/reset of pro-
grams and practices will follow. The next two chapters set the context for that conver-
sation, and they are explored for that purpose, rather than a detailed thesis on the
below topics.
Chapter Abstracts
– Chapter 1 explores, at the top level, definitions, construct, purpose of risk, and its
management, as risk and value are two sides of the same coin. The purpose is to
touch on the fundamentals that hold true across time and across risk categories.
This chapter will be cross-referenced when we discuss concepts of climate change
risk.
– Chapter 2 briefly looks at the different flavours of risks, the important ones, that
banks work with. The idea is to emphasise that there is truly no standalone risk –
each category impacts the other. The overall health of the organization is in creat-
ing a positive collaboration and correlation across the various categories. Some of
the risk categories discussed here and their links with climate change risk will be
explored in subsequent chapters.
Chapter 1
An Overview of Risk and Risk Management
in Banks
Opportunity and risk come in pairs. –Bangambiki Habyarimana, The Great Pearl of Wisdom
“Risk” in its broadest sense is the probability of winning or losing something of value.
Good management of this core element of business is to optimize the wins and arrest
the losses to manageable levels. It is because of this fine balance that this discipline is
an art, craft, and science rolled into one: an art required to visualize something that is
not apparent, a craft/skill to spot the risks in time, and science that facilitates objec-
tive measurement and management.
Risk
Risk is a business reality and affects almost every decision the business takes. The
only choice that businesses have is whether to take it or not. If the former, then this
involves putting in appropriate controls for an optimized outcome. Risk occurs when
there is hazard, exposure and vulnerability at the same time. Understanding “risk” is
foundational to its “management.” Risk as a term is used in multiple contexts, with
the most used the likelihood of quantifiable loss. There are a couple of interesting hor-
izontal definitions/explanations I came across that are simple yet interesting and illus-
trative at the same time. The first brings out the contours of risk (and a smile as well)
detailed as five sub-themes:
– Risk = an unwanted event which may or may not occur
– Risk = the cause of an unwanted event which may or may not occur
– Risk = the probability of an unwanted event which may or may not occur
– Risk = the statistical expectation value of an unwanted event which may or may
not occur
– Risk = the fact that a decision is made under conditions of known probabili-
ties (“decision under risk” as opposed to “decision under uncertainty”)1
The definition lucidly brings to fore a couple of critical aspects of risk (in addition to
others). The first is the possibility of an unwanted event happening and the second is
the preparedness for that possibility that aids decision-making in the event of risk.
The other quote that I like, explains the distinction between risk and uncertainty,
“To preserve the distinction . . . between the measurable uncertainty and an immea-
Sven Ove Hansson, “Risk,” The Stanford Encyclopedia of Philosophy (Spring 2014 Edition), ed.
Edward N. Zalta, http://plato.stanford.edu/archives/spr2014/entries/risk/.
https://doi.org/10.1515/9783110757958-002
10 Chapter 1 An Overview of Risk and Risk Management in Banks
surable one we may use the term “risk” to designate the former and the term “uncer-
tainty” for the latter.”2 This one highlights “measurability.”
These two bring together the core facets of risk, that of identifying the vulnerable
events and the ability of quantifying them. Typically risk and its definitions are asso-
ciated with loss, with the exception to this rule being the ISO definition of risk, as the
“effect of uncertainty on objectives.”3 In this definition, uncertainties include events
(which may or may not happen) and uncertainties caused by ambiguity or a lack of
information. It also includes both negative and positive impacts on objectives. This
definition broadens the scope and impact of “risk’ to include both sides of the likeli-
hood. This is a realistic definition as it acknowledges the fact that risks may result in
either gain or loss. Interestingly, risk can result from action or inaction, the latter re-
sulting in opportunity loss.
Table 1.1 looks at the primary terms used and their dictionary definitions. Impor-
tant to understand that these are horizontal definitions not contextualized to how
banks use them. However, they serve the vital function of setting the right apprecia-
tion of the terms.
(Merriam Webster)
Some nuances:
– An important fact to keep in mind is that hazard by itself does not lead to risk
with negative impact unless there is exposure at the same time to that hazard.
Both hazard and exposure need to occur simultaneously for loss to happen. The
magnitude of loss is dependant on the firm/location specific vulnerability.
Some of the terms appear to be similar or synonymous but a closer examination re-
veals the differences and these are fundamental to interpretation of the nuances of
the subject and provides the required insights to appreciate the contours of risk. Each
of the themes below have been the subject of a great amount of discussion, debate,
research, and the resultant literature. Given that the objective here is to set a founda-
tional understanding, the distinction has been presented in simple terms in Table 1.2
for this to be appreciated.
Table 1.2: The principal distinction between common terms that are mistaken as synonyms.
Risk vs. Uncertainty “The concept of risk is distinct from uncertainty. The former relates to that which
can be predicted, measured, or quantified whereas the latter relate to “unknown
unknowns” and “known unknowables” where outcomes and probability
distributions cannot be meaningfully defined.” The main point here is that risks
can and should be measured while uncertainty cannot.
Hazard vs. Risk An important distinction is that while risk is a potential of downside (or upside),
hazard is the possible source of loss. Another important difference is that while
risk could lead to loss or gain, the outcome of hazard is always harmful.
Risk vs. While risk is the possibility of loss (or gain in some cases) vulnerability is
Vulnerability organization specific. Two organizations exposed to similar risk with potential
downside and exposure may not suffer the same quantum of loss due to their
differing vulnerability level.
Likelihood vs. Probability is associated with possible results; likelihood is associated with
Probability hypothesis.
Probability is usually expressed as a numerical value – a proportion that ranges
from to or as a percentage ranging from % to %. Likelihood, on the other
hand, is typically expressed as a scale – low, medium, high, very high, etc.
Sanjeev Sanyal, Principal Economic Adviser, Risk Vs Uncertainty: Supervision, Governance & Skin-
in-the-Game – Discussion Paper No. 1/2020-DEA Feb 2020.
12 Chapter 1 An Overview of Risk and Risk Management in Banks
Innovation and opportunity go hand in hand with risk because optimizing the
positive outcome of a risk taken is dependent on an intelligent approach to managing
the context presented. This is where a well-structured risk management ecosystem
comes into play.
Risk Management
This part begins with two quotes from regulators’ documents that capture the essence
of risk management in banks and financial institutions from a structure and process
perspective:
Financial institutions are in the business of risk management and hence are incentivised to de-
velop sophisticated risk management systems. The basic components of a risk management sys-
tem are identifying the risks the entity is exposed to, assessing their magnitude, monitoring
them, controlling, or mitigating them using a variety of procedures, and setting aside capital for
potential losses (including expected and unexpected losses).5
Risk management . . . encompasses the process of identifying risks to the bank, measuring expo-
sures to those risks (where possible), ensuring that an effective capital planning and monitoring
programme is in place . . . 6
The first one clearly states that financial institutions are “in the business of risk man-
agement” – that of taking risks and managing them. When confronted with risk that
would impact their books (Balance Sheet and/or P&L Statements) organizations have,
broadly, three options:
– Risk avoidance (a non-option for going concerns though definitely a situational option)
– Risk Transfer or risk hedging.
– Risk acceptance – of risks that fall within a clearly stated risk appetite with proactive and
executable controls that will help mitigate the downside.
Every going concern has or is expected to put in place a robust risk management
framework. The basis of a sound framework is its ability to take “controllable” risks
which can be measured/quantified with assignable probabilities of potential upside
and the significant downside. Risk management is simple in terms of its objective –
managing risks an organization faces in a way that negative impact is minimized and
positive impact is optimized. The word “optimized” is consciously used as opposed to
“maximized,” as every opportunity has a cost, and it is the ability to achieve balance
that ensures growth.
Risk
Consciousness
&
Risk Reporting Organizational
& Monitoring Resiliency
Risk Appetite
Process
Improvement
& Training
Risk Identification
& Prioritization
Simply put, risk management is the construct that enables organizations to identify,
assess, and control risks that affect their capital and revenue. Risks could stem from
multiple sources that are both financial and/or non-financial, internal or external,
and natural disasters – the list is long. The ability to examine the link between risks
taken and the impact they have on the strategic objectives of the organization is core
Carnegie Mellon University Risk Operations – Enterprise Risk Management, Defining Enterprise
Risk Management (ERM), https://www.cmu.edu/risk-operations/erm-framework/index.html.
14 Chapter 1 An Overview of Risk and Risk Management in Banks
to the program. Like I said earlier, the objective of risk management is not to elimi-
nate risks but to manage them in a way that they preserve and grow organizational
value by enabling management to make informed decisions.
Risk avoidance is not an option as it is part of and affects every action of the firm.
It is much bigger than mere risk transfer and risk hedging. The successful firms have
learnt or are learning to have the right balance between the upside and the downside
realistically. Figure 1.2 captures the basic tenet of desirable and undesirable risks.
Desirable Undesirable
risk risk
Healthy Sizeable
upside downside
Limited Uncertain/
manageable limited
downside upside
The above is idealistic. The real-life situations lie somewhere in-between, and actions
taken depend on the risk appetite, control systems, and potential size of the impact on
the books of the bank. There needs to be a structured approach by design. The underly-
ing canvas has multiple currents and cross currents, effect and counter effects, and in-
terdependencies that are challenging. The effort is as much to manage negative risk
(avoid, transfer, hedge, control, etc.) as it is to spot and leverage positive risks that add
value or, on the other hand, affect the capital or P&L of the organization if not taken.
Risk management is the function of making choices by the organization amongst
the alternatives, based on their risk appetite, to pursue courses of action of measur-
able and controllable losses (or gain) in its pursuit of value. It is about prioritizing
and acting based on reliable information to enable better decisions, thus ensuring sus-
tainable growth. The three foundational aspects of the flow are:
– Evaluation process:
– To establish with reasonable certainty the potential of upside or downside – normally
a logical and methodical activity.
– Ensuring that the required controls are in place to counter or reduce the negative im-
pact if risks are accepted.
– Decision Process:
– Management decisions, based on the above, to accept or reject the risk
– Execution Process:
– Execution of the decisions
– Monitoring the outcomes and speedy course correction if and when required
Figure 1.3 captures the material components of the risk management process of a bank.
Risk Management 15
Identification
Assessment
Monitoring &
Likelihood &
Mitigation
Commun- Probability
ication Commun-
Channels Risk Appetite ication
& Channels
Risk Tolerance
Acceptance if Quantification
Aligned with Impact –
Corporate Exposure @
Objectives Risk
Controls &
Their
Effectiveness
The centerpiece to a good risk management flow is putting in place a robust risk
information management system (RIMS) that communicates costs, risks, controls in
place, and the benefits in a quick, simple, transparent, and relatable way. Accurate
and timely availability of information is at the heart of an effective RIMS. A good
RIMS is the oil that lubricates and ensures smooth operation of the risk function and
is crucial to its success. The practical choice needs to be “appropriate technology” as
opposed to “latest technology.” The appropriateness is determined by the size of the
organization, their major and material risk categories, and the geographies of opera-
tions. In short, the internal and external realities of the organization.
The challenge of risk management is to keep it simple and usable. While the pro-
gram must consider the full range of risks it faces, it will make sense to keep “mate-
rial” risks as the focus, as opposed to all risks. It is advisable to have an overall
approach, governance, and business ethics-based ground rules as applicable across
the spectrum. For the identified material risks, the entire gamut starting from risk ap-
petite, identification, assessment, measurement, mitigation, and controls that are rele-
vant to that risk category need to be clearly spelled out, communicated and tracked.
The non-material risks can be managed through good governance and ground rules
referred above.
16 Chapter 1 An Overview of Risk and Risk Management in Banks
From a standards and frameworks perspective, ISO 310008 and COSO9 frame-
works for enterprise risk management are good references. A good summary of the
weaknesses that need to be taken care of while designing a risk management system
has been nicely summarized by Paul Hopkins as follows:
Failure to adequately manage the risks faced by an organization can be caused by inadequate
risk recognition, insufficient analysis of significant risks and failure to identify suitable risk re-
sponse activities, failure to set a risk management strategy and to communicate that strategy and
the associated responsibilities may result in inadequate management of risks. Risk management
procedures or protocols may be flawed, such that these protocols may actually be incapable of
delivering the required outcomes.10
At the end of the day, the measure of a good risk management construct is the ability
it provides the decision makers to decide which risks to sidestep, which to pass-
through, and which to take on for value creation. Progressive organizations have this
as an important evaluation criterion of their risk managers. In the ultimate analysis,
some risk will be passed through to the investors, some will be hedged or insured,
and some actively pursued. The wisdom is really in making the right choices at the
right time.
If you don’t invest in risk management, it doesn’t matter what business you’re in, it’s a risky business.
–Gary Cohn
The fabric of risk is woven together with multiple threads in complex patterns, some
by design and others by default or accident. Oftentimes, there is also the ignorance or
plain carelessness of the weavers (stakeholders), either internal or external. For un-
derstanding purposes, it is good to look at the different risks, the major ones, in
slightly more detail. This chapter will focus on five major categories of risk that have
direct bearing on the financial impact of climate change risks on banks. Each of the
major risk categories mentioned in this chapter has an extensive amount of literature
focused on every detail of the subject, both from an academic perspective as well as
application oriented. The objective of this chapter is to provide a bird’s eye view of
the different risk categories, with the intention to explore the interlinks with and im-
pact on climate change risk in later chapters.
Figure 2.1 lists the Risk Categories at the top level as a start point. It is important
to mention, however, that there is nothing like “non-financial risk” in the long run as
all risk categories will have financial implications, either on the balance sheet or the
profit and loss statement of the organization sooner or later. The only major differen-
ces are the timing, when the organization will take a hit (if not controlled), and
whether the impact can be measured upfront, reasonably and objectively. Non-
financial risks are more difficult to measure. Figure 2.2 looks at risk classification at
slightly more detail, giving examples of financial and non-financial risks.
Risk categories
https://doi.org/10.1515/9783110757958-003
Chapter 2 The Different Flavors of Risk that Banks Work With 19
Risk types
Liquidity &
Credit risks Market risks interest rate Operational Strategic Reputational
risks
People &
Customers Technology
processes
related related
related
Another view of segmenting risks of the bank is provided by regulators who are
concerned with the capital adequacy and relative buffers that the organization should
keep to cover its risk profile. This view is captured in Figure 2.3. The classification
seems to be largely centered on two aspects – the measurability and the potential of
hit on capital. For Pillar 1 components, regulators articulate capital to be set aside,
their quantification methods, and algorithms. This set is seen as more “objective,”
more “measurable,” more “predictable,” and having a higher impact on capital. Pillar
2 risks, on the other hand, are more difficult to “quantify” from a capital perspective.
The assessment of adequacy of capital to cover these risks are left to the individual
banks, subject to the overall guidance and supervision of regulators.
It is interesting to note that operational risk is classified under the Pillar 1 cate-
gory for capital adequacy purposes, but under non-financial risks from a typical risk
categories classification. In the case of liquidity risk the reverse is true – Pillar 2 for
capital adequacy and financial risk from a traditional perspective. The real insight is
that while classifications are based on the objective, all risks at the root will impact
banks, if not managed well.
Figure 2.4 captures a slightly different view1 of risks, highlighting the operational
risk sub-types in some detail.
Analytical and
Policy Risk
IT Systems
Risk
Human Bank
Operational Resources Analytical & Liquidity Risk
Control Risk Risk Policy Risk
Bank Bank
Project Risk Operational Financial Credit Risk
Risk Risk
Business Compliance
Disruption and Business Market Risk
Risk Practice Risk
Financial risks have been the focus of banks for decades in a regulated world and for
centuries as part of businesses. The big blocks here are credit risk (the possibility that
borrowers and counterparties may not honor agreed terms), market risk (the possibil-
ity that value of market instruments they hold will fluctuate adversely), and liquidity
risk (potential inability of the bank to meet its maturing obligations to its depositors
and counterparties).
It is the non-financial risk categories (NFR) that are adding to the ever-expanding
canvas of the risk universe. As this book goes into publication, the landscape of NFR is
captured in Figure 2.5 with each of the categories having multiple sub-types and con-
stantly evolving. The reason why NFR is a critical area, be it ongoing compliance failures,
operational challenges or the more recent pandemic related or the upcoming climate
change/ESG risks, is that they often have only downside if not managed well and the
downside will be substantial. It is not just about the financial loss through fines and com-
pensations, etc., but also the collateral damage of reputation loss, not to mention per-
sonal consequences for senior role holders.
The interlinks between risk categories and each impacting the other is a given,
but in NFRs these are more pronounced. What is of concern, in recent times, is the
acceleration of intertwining of financial and non-financial risk, with a negative multi-
plier effect.
Strategic risks
Reputation risk
Operational risks: people, processes, IT, etc., related
Traditional Legal risk
Compliance risk
Conduct risk
Model risk
Non-financial risks
Pandemic, natural disasters
Climate change/ESG risks
Digital disruption
More recent areas Cyber risk
Third party risk
Data breaches/privacy
Others…
Having set the broader canvas of risk categories and risk types, we now move to take
a quick and high-level view of the material risks that banks carry in their books, espe-
cially the ones that have significant interlinks with climate change risks.
Credit Risk
This is the biggest category of risks on the bank’s books. It is the potential that the
bank’s borrower or counter party defaults on honoring agreed terms of repayment:
“Credit risk or default risk involves inability or unwillingness of a customer or
counter party to meet commitments in relation to lending, trading, hedging, settle-
ment and other financial transactions.”2 As financial intermediaries, banks accept de-
posits and lend, with lending, usually, being the biggest chunk of their balance sheet
and as such one of its big concerns. While capital and its buffers support to some ex-
tent in occasional cases of losses (defaults), they cannot be a substitute to well man-
aged credit risk. The risk of non-recovery of funds (both principal and interest) in a
timely fashion due to the default of its customers or counter parties will severely im-
pair the ability to honor its obligations, a situation a bank cannot afford.
Having been a banker myself, I remember during our initial training days having
it ingrained into us that the worst nightmare a bank can have is a “run” on it. A run
on the bank happens when depositors lose confidence on the bank and want to with-
draw “everything” they hold with the bank. This could happen due to a combination
of uncontrollable credit risk and insufficiency of immediate liquidity (liquidity risk).
Inadequate or faulty processes (operational risk) could add to the milieu, as witnessed
during the 2007–08 financial crisis.
The real capital banks hold is the trust of their customers. An unmanaged credit risk
may lead to losing that trust, which is why it is one of the most important risks to be
managed well. Credit risk exists both at portfolio level and at individual borrower level,
not to mention interbank transactions, trade financing, and derivatives. It can come in
various shapes, the most common being default risk. The other forms can be concentra-
tion risk, downgrade risk, and the like. Some happen across their on-balance sheet busi-
nesses like mortgages, credit cards, term loans, and securities under their investment
portfolio while others happen across their off-balance sheet businesses like guarantees,
derivatives, etc. Some add country risk into the mix, while some bracket it under market
risk, though most prefer to look at it as a separate risk category altogether.
Market Risk
“Market risk is defined as the risk of losses arising from movements in market prices.
The risks subject to market risk capital requirements include but are not limited to
– Default risk, interest rate risk, credit spread risk, equity risk, foreign exchange
(FX) risk and commodities risk for trading book instruments; and
– FX risk and commodities risk for banking book instruments.”3
All market participants face market risk, a systematic risk that cannot be eliminated
through diversification, and hence all of them look for optimal hedging mechanisms.
Essentially, market risk is the risk caused by changes in markets that it operates in
and is a measure of the various factors affecting the performance of financial markets
they operate in. The risk stems from adverse movement of prices of financial instru-
ments. This can come from adverse directional change of stock prices, commodity pri-
ces, interest rates, exchange rates or non-directional change in the form of volatility
Definitions and application of market risk, BCBS MAR 11 (version effective January 1, 2023).
Liquidity Risk 23
risks. The sub-types of market risk that confront banks are, largely, equity risk, com-
modity risk, forex risk, and interest rate risk.
An interesting trivia on interest rate is that “for over 300 years, the official interest
rate has been positive (more than zero). The earliest rate we have on record was 6% in
1694. Since then, the official interest rate has ranged from 17% (in November 1979) to
0.1% (in March 2020).”4 This range from 17% to 0.1% gives a glimpse into the volatility
and impact the periodic changes will have on the portfolio of a bank. This is data from
one regulator; multiply it by the many regulators and their stance on interest rates,
some of whom have implemented negative interest rates at points in time (e.g., Japan,
Denmark, Sweden, Switzerland, etc.).
Market risk a global bank is exposed to, as it operates under multiple interest
rate scenarios across multiple geographies simultaneously, can well be appreciated.
The interest rate is only one of the factors: add to it the volatility of the other factors
like forex rates, commodity prices, and equity prices, all constantly in a state of flux
both within a given market and across markets. The resultant is the canvas of many
moving parts, a kaleidoscope with images changing by the minute, that banks need to
deal to manage their market risk. This explains why it is a highly sophisticated area
both from the information systems and technology as well as the people that support
the function.
Liquidity Risk
This is the risk associated with the bank’s inability to meet its obligations, in a timely
manner, at viable cost, which it is forced to do through distress borrowing at high
costs. Liquidity is the bloodline of a bank – it enables asset growth and meeting of
obligations, both cash and collateral, at acceptable costs. The risk typically arises be-
cause of funding long term assets with short term liabilities, from a maturity mis-
match between its assets and liability profile with over reliance on short term sources
of funds. It stems from illiquid assets in the bank’s books too. The two components of
liquidity risk are funding liquidity risk and market liquidity risk: “Funding liquidity
risk is the risk that a firm will not be able to meet its current and future cash flow
and collateral needs, both expected and unexpected, without materially affecting its
daily operations or overall financial condition.”5
“Market liquidity risk relates to the inability of trading at a fair price with imme-
diacy. It is the systematic, non-diversifiable component of liquidity risk.”6 Insufficient
buyers against sell orders and insufficient sellers against buy orders exacerbate the
situation in a liquidity challenged position.
Central bank liquidity is an important factor in providing sufficient liquidity to
balance the demand and supply. There is constant flow across funding liquidity, mar-
ket liquidity, and central bank liquidity.
Operational Risk
“Operational risk is defined as the risk of loss resulting from inadequate or failed in-
ternal processes, people, and systems or from external events. This definition includes
legal risk but excludes strategic and reputational risks.”7 While losses from any risk
category can be high, operational risk losses can be catastrophic both financially as
well as reputationally. The combined impact on business is, to say the least, very high.
These are the risks that emanate from “how” day to day operations are con-
ducted, as opposed to “what” businesses a firm is focused on (which are covered by
financial risks like credit, market, and liquidity risks). Most of the risk drivers under
this category are specific to a given organization and its operating model, hence “un-
systematic” to a large extent, except events like natural disasters and acts of terrorism
which are external in nature.
Every organization faces operational risks triggered by both internal and external
factors that could be due to mistakes (willful or otherwise), breaches of policies and
procedures, work disruptions, or damages. Examples of internal causes can be through
their people, processes, technology, etc. The external causes can be natural disasters,
terrorist activities, third party partners, etc. Internal and external frauds, litigations
and legal risks due to faulty processes, damage to assets due to disasters, and business
disruptions due to system failures are some other examples.
Reputational Risk
Reputational risk is the threat of negative perception or actual hit on the reputation
and standing of an organization, either directly through the actions of the organiza-
tion and/or its employees or indirectly through connected parties. Brand value is in-
dicative of the reputation an organization enjoys. While reputation risk can stem
Kleopatra Nikolaou, Liquidity (Risk) Concepts, Definitions and Interactions European Central
Bank – Working Paper Series – NO 1008/February 2009.
BCBS 195, Principles for the Sound Management of Operational Risk (June 2011).
Interpretation Risk 25
from actual actions of the bank, at times it could happen due to negative publicity
(true or otherwise) or employee fraud that they have perpetuated, taking advantage
of loopholes in processes or lax governance structures. While the actual act in the lat-
ter case falls within operational risk realm, the perception of dishonesty impacts the
credibility of the organization and therefore its reputation. This could result in the
bank’s inability to raise capital or borrowings on favorable terms, a simple illustra-
tion of how the apparently different risk categories are intrinsically interconnected.
Interpretation Risk
A special mention needs to be made of an important but less spoken of risk, which I
call, “the Interpretation risk.” This “is the risk of likely differing interpretations of am-
biguous, untested or elaborate laws, regulations and standards.”8 While this is ex-
tremely relevant in the compliance risk space, it is equally or perhaps more relevant
in climate change risk space as this area has a double challenge in terms of there
being multiple elaborate standards, disclosure requirements, policy guidelines, etc. on
the one hand and the subject itself being new and evolving on the other. When I first
used the term, “Interpretational Risk,” in the context of compliance risk, my banker
friends said this perhaps is the biggest category risk they face because a lot of material
is subject to interpretation. This is equally or more relevant in the climate change risk
space, and therein lies the need for global standards which will be discussed across
the book but more specifically in Parts three and five.
In summary, banks face risks that go beyond their customer portfolios (deposits
and loans) and beyond rising or falling markets. As we move forward, data breaches,
pandemic risk, climate change risk and its financial impact on the organization, and
geopolitical risks will add to the milieu of risks. A reality check is that no matter how
vigilant the risk management function of a bank is, it is not possible to foresee or plan
for every contingency. It is here that scenarios and stress designing help, where bank-
ers try and visualize black swan events. Even then, the expectation that they can fore-
see every situation is remote, as it is outside of their experience or visualization
capability. It is for this reason that a sound governance construct and fundamental
risk management principles and processes need to form the bedrock of the enterprise
risk management constructs of the bank, so they form the first level safety net.
Events/situations that have the potential of disrupting business, either exploding
on the horizon suddenly or stealthily coming in, will happen periodically. These,
while arising in one risk type, will also impact other risk types. The more risk types
that get impacted, the higher the magnitude of loss for a given bank. If this situation
Saloni P. Ramakrishna, Enterprise Compliance Risk Management – An Essential Toolkit for Banks
and Financial Services (2015), Wiley.
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alike; maintaining his official neutrality with a meek and modest
dignity that nothing could disturb, or ruffle for a moment; and
soothing his old age with Christian philosophy, and polite letters, and
the "sweetly-uttered wisdom" of poesy, which he had always loved
from his youth—and we tendered him the office. He accepted it, Sir,
at once, with that gracious condescension which belonged to him—
expressed his cordial concurrence in our views—presented us with
his own immortal work, the Life of the Father of his Country—and
stamped our enterprise with the seal of his decisive approbation.
After this, Sir, we naturally felt a new interest in him; and you
remember Sir, I dare say, how our hearts flowed out to him with a
sort of filial reverence and affection, as he came about amongst us,
like a father amongst his children, like a patriarch amongst his
people—like that patriarch whom the sacred Scriptures have
canonized for our admiration—"when the eye saw him, it blessed
him: when the ear heard him, it gave witness to him; and after his
words men spake not again." For his words, indeed, even in his most
familiar conversation, fell upon us with a sort of judicial weight; and
from his private opinions, as from his public decisions, there was no
appeal. Happy, thrice happy old man! How we wished and prayed for
the continuance of his days, and of all the happiness and honor
which he had so fairly won, and which he seemed to enjoy still more
for our sakes than for his own! We gazed upon him indeed, Sir, as
upon the setting sun, whilst, his long circuit of glory almost finished,
he sank slowly to his rest; admiring the increased grandeur of his
orb, and the graciousness with which he suffered us to view the
softened splendors of his face; but with a mournful interest, too,
which sprang from the reflection that we should soon lose his light.
And we have lost it indeed. He has left us now—and we mourn for
his departure. But we are consoled, Sir, by the transporting
assurance which we feel, that the splendid luminary which the
benificent Creator had kindled up for the blessing and ornament of
our native land, and of the world, is not gone out in darkness, but
shines still with inextinguishable lustre in the firmament of Heaven.
AN ADDRESS,
1 "It being understood that Professor Dew has been prevented by delicate health and
the inclemency of the season, from attending the present meeting—
In the first place, it has been affirmed that republics are too
economical—too niggardly in their expenditures, to afford that
salutary and efficient patronage necessary to the growth of literature.
To this I would answer, first, that this argument takes for granted that
the literature of a nation advances or recedes in proportion to the
pecuniary wages which it earns. Now, although I do not say with Dr.
Goldsmith, that the man who draws his pen to take a purse, no more
deserves to have it, than the man who draws his pistol for the same
purpose, yet I may safely assert, that of the motives which operate
on the literary man—the love of fame, the desire to be useful, and
the love of money—the former, in the great majority of cases, exerts
an infinitely more powerful influence than the latter. And if I shall be
able to show, as I hope to do in the sequel, that the republican form
of government is the one which is best calculated to stimulate these
great passions of our nature and throw into action all the energies of
man, then must we acknowledge its superiority, even in a literary
point of view.
But the men who most adorned the various departments of learning
during the long reign of Augustus, were born in the last days of the
republic. They saw what the glory of the commonwealth had been—
they beheld with their own eyes the greatness of their country, and
they had inhaled in their youth the breath of freedom. No Roman
writer, for example, excels the Lyric Bard in true feeling and
sympathy for heroic greatness. We ever behold through the medium
of his writings—even the gayest—a deep rooted sorrow locked up in
his bosom, for the subversion of the liberties of the commonwealth.
"On every occasion we can see the inspiring flame of patriotism and
freedom breaking through that mist of levity in which his poetry is
involved." "He constrained his inclinations," says Schlegel, "and
endeavored to write like a royalist, but in spite of himself he is still
manifestly a republican and a Roman."2
2 Horace fought under Brutus and Cassius, on the side of the Republic, at the battle
of Philippi, and he was after the battle saved from the wreck of the republican army,
and treated with great respect and kindness by Augustus and his minister Mecænas.
"In the last years of Augustus," says the same writer, "the younger
generation who were born, or at least grew up to manhood, after the
commencement of the monarchy, were altogether different. We can
already perceive the symptoms of declining taste—in Ovid
particularly, who is overrun with an unhealthy superfluity of fancy,
and a sentimental effeminacy of expression." Even History itself, in
which the Romans so far excelled, yielded to the corrupting influence
of the Cæsars. Tacitus concluded the long series of splendid and
vigorous writers, and he grew up and was educated under the
comparatively happy reigns of Vespasian and Titus, and wrote under
the mild government of Nerva. Unnatural pomp and extravagance of
expression seem, strange as it may appear, to be the necessary
results of social and political degradation. And it is curious indeed to
behold among the writers under the first Cæsars, the extraordinary
compounds which genius can produce, when impelled on the one
hand by the all-powerful and stimulating love of liberty, and vivid
glimpses of the real dignity of human nature, while checked and
subdued on the other by the fear of arbitrary power. Take Lucan for
an example. "In him we find the most outrageously republican
feelings making their chosen abode in the breast of a wealthy and
luxurious courtier of Nero. It excites surprise and even disgust, to
observe how he stoops to flatter that disgusting tyrant, in
expressions the meanness of which amounts to a crime, and then in
the next page, exalts Cato above the Gods themselves, and speaks
of all the enemies of the first Cæsar with an admiration that
approaches to idolatry."
Thus do we see that it is only the lighter kinds of literature, and the
physical and mathematical sciences, which the patronage of a
monarch can be expected to foster. In those nobler and more useful
branches of knowledge—moral, mental, religious, and political,—the
patronage of the throne clips the wings of philosophy and arrests the
growth of science and the progress of truth.3
3 In the great Austrian University established at Vienna, the Professor of Statistics is
strictly forbidden to present to the view of his class any other Statistics than those of
Austria, lest this country should suffer by comparison with others. How limited must
be the range of intellect on political subjects under such fatal restrictions as this,
imposed by the narrow jealousy of arbitrary power!
The only additional remark which I shall make upon the general
question of the relative influences exerted upon the progress of
literature and the development of character, by the monarchical and
republican forms of government is, that in the former the aspirants to
office and honors look upwards to the throne and the nobility, in the
latter they look downwards to the people. This simple difference
between the two governments is calculated to produce the most
extensive and material consequences. In the first place, the kind of
talent requisite for success under the two governments, is very
different. Even Mr. Hume himself acknowledges, that, to be
successful with the people, it is generally necessary for a man to
make himself useful by his industry, capacity, or knowledge; to be
prosperous under a monarchy, it is requisite to render himself
agreeable by his wit, complaisance, or civility. "A strong genius
succeeds best in republics: a refined taste in monarchies. And
consequently the sciences are the more natural growth of the one,
and the polite arts of the other." We are told, that in France under the
old monarchy, men did not expect to reach the elevated offices of
government either by hard labor, close study, or real efficiency of
character. A bon mot, some peculiar gracefulness, was frequently
the occasion of the most rapid promotions; and these frequent
examples, we are told, inspired a sort of careless philosophy, a
confidence in fortune, and a contempt for studious exertions, which
could only end in a sacrifice of utility to mere pleasure and elegance.
The fate of individuals under those circumstances is determined, not
by their intrinsic worth or real talents, but by their capacity to please
the monarch and his court. Poor Racine, we are told by St. Çimon,
was banished forever from the royal sunshine in which he had so
long basked, because in a moment of that absence of mind for which
he was remarkable, he made an unlucky observation upon the
writings of Scarron in presence of the king and Madame de
Maintenon, which could never be forgotten or forgiven. We all know
that the Raleighs, Leicesters, Essexes, &c. under the energetic reign
of Elizabeth, were much more indebted to their personal
accomplishments and devoted and adulatory gallantries, for their
rapid promotions, than to any real services which they had rendered,
or extraordinary talents which they had displayed. And in the time of
Queen Anne, it has been said that the scale was turned in favor of
passive obedience and nonresistance, by the Duchess of
Marlborough's gloves; and the ill humor of the Duchess caused the
recall of Marlborough, which alone could have saved the kingdom of
France from almost certain conquest at that eventful crisis.
But how debasing does this form of government become, when the
monarch, either from policy or inclination, shuns the talent and virtue
of the country, addresses himself to the lowest, the most vulgar and
most selfish passions of man, and draws around him into the high
places of the government men taken from the lowest and most
despised functions of life. "Kings," says Burke, "are naturally lovers
of low company; they are so elevated above all the rest of mankind
that they must look upon all their subjects as on a level." They are
apt, unless they be wise men, to hate the talent and virtue of the
country, and attach themselves to those vile instruments who will
consent to flatter their caprices, pander to their low and grovelling
pleasures, and offer up to them the disgusting incense of
sycophantic fawning adulation. Every man of talent and virtue is an
obstacle in the path of such a monarch as this—he holds up to his
view a most hateful mirror. When such monarchs as these are on the
throne, the government exercises the most withering influence on
the intellect and virtue of the country. Science is dishonored and
persecuted because she is virtuous, because she will consent to
flatter neither the monarch on his throne nor his sycophantic courtier
—she will consent to mingle in no degrading strife, nor does she
bring up any reserve to the dishonest minister, either to swell his
triumph or to break his fall. When men of rank thus sacrifice all ideas
of dignity to an ambition without a useful and noble object, and work
with low instruments and for low ends, the whole composition
becomes low and base. Whilst Tiberius surrenders himself into the
keeping of so vile a being as Sejanus—whilst Nero is fiddling and
dancing, and Commodus in the arena with the gladiators—all that is
noble and great in the empire must retire into the shade and seek for
safety in solitude and obscurity.
When Louis XI dismissed from the court those faithful nobles and
distinguished citizens, who had stood by his father and saved the
monarch and his throne in the hour of adversity, and filled their
places with men taken from the lowest and meanest condition of life,
with no other merit than that possessed by the eunuch guard of the
Medio-Persian monarch, of adhering to the king, because despised
by all the world besides, he conquered, for the time at least, the
virtue, the chivalry, the real greatness of France. Well, then, may we
say, in the emphatic language of England's most philosophic
statesman, "Woe to the country which would madly and impiously
reject the service of the talents and virtues, civil, military or religious,
that are given to grace and to serve it; and would condemn to
obscurity every thing formed to diffuse lustre and glory around a
state. Woe to that country too, that considers a low education, a
mean contracted view of things, a sordid, mercenary occupation, as
a preferable title to command."
But it may be asked, may not some of the effects which I have just
described as flowing from monarchy, be produced under the
republican form of government? To this I answer that almost all of
them may be expected to be the result of one homogeneous
republic, stretching over a great extent of territory, including a
numerous population and a great diversity of interest; but, as such a
government as this has been wisely provided against in our country
at least, by a system of confederated republics, I will now proceed to
the main object of my discourse this evening—to point out the
peculiar influence which our federative system of government is
calculated to produce upon literature and character.
Since the governments of the world have become more regular and
stable, and the great expense of war has made even victory and
conquest ruinous to nations, rulers are beginning to look to the
development of the internal resources of their countries, more than
to foreign conquest and national spoliations. The great system of
internal improvement in all its branches, is without doubt one of the
most powerfully efficient means which can be devised to hurry
forward the accumulation of wealth, and speed on the progress of
civilization. The canal and the rail road, the steam boat and the
steam car, the water power and steam power, constitute in fact the
great and characteristic powers of the nineteenth century—they are
the mighty civilizers of the age in which we live. They bind together
in harmony and concord the discordant interests of nations, and like
the vascular system of the human frame, they produce a wholesome
circulation, and a vivifying and stimulating action throughout the
whole body politic.
These great improvements in our own country, with but few
exceptions, and those well defined, ought to be executed solely by
states and individuals. But neither states nor individuals would
execute those necessary works, without security from interruption
and invasion, and consequent security in the enjoyment of the profits
which they might yield. What wealthy individual in our own state, for
example, would erect a costly bridge across one of our rivers, or
embark his capital in the construction of a canal or rail road, if foe or
friend might blow up his bridge during the next year, or a war might
interrupt trade, and perhaps a treaty of peace might cede the canal
or rail way to a different state?
Of all the nations in Europe, England is the one which has been
most exempt from foreign invasion, and we find in that country that
individual enterprise has achieved more in the cause of internal
improvement than in any other nation in Europe; and the prosperity
and real greatness of England are no doubt due in a great measure
to the energy and enterprise of her citizens. In the continental
nations we find this constant liability to invasion every where
paralyzing the enterprise of both individuals and states. One of the
most skilful engineers of France tells us that in passing through
some of the frontier provinces of that country, he every where beheld
the most mournful evidences of the want of both national and
individual enterprise, in miserable roads, in decayed or fallen
bridges, in the absence of canals and turnpikes, of manufactures,
commerce, and even of agriculture itself, in many almost deserted
regions. Paris, the second city in Europe in point of numbers and
wealth, and the capital of the nation hitherto most powerful on the
continent, has not yet in this age of ardor and enterprise, constructed
either a canal or rail road to the ocean, or even to any intermediate
point. If our federative system contained within its borders a city thus
wealthy and populous, and so well situated, can there be a doubt
that it would long ere this have sent its rail roads and canals not only
to the ocean, but in all probability to the Rhine and the Danube, to
the Rhone, the Garonne, and the Mediterranean.
This spirit of improvement, under the hitherto benign protection of
our government, is already abroad in the land. New York and
Pennsylvania have already executed works which rival in splendor
and grandeur the boasted monuments of Egypt, Rome or China, and
far excel them in usefulness and profit. The states of the south and
west too are moving on in the same noble career. And our own
Virginia, the Old Dominion, has at last awakened from her inglorious
repose, and is pushing forward with vigor her great central
improvement, destined soon to pass the Blue Ridge and Alleghany
ranges of mountains, and thus to realize the fable of antiquity, which
represented the sea-gods as driving their herds to pasture on the
mountains.