The Failure of Risk: lessons from the GFC Reply

risk management. hop scotchWe live in uncertain times. The failures in risk management which lead to the global financial crisis have created an unprecedented set of circumstances. Not only are regulators imposing heavier compliance burdens but shareholders and investors are demanding greater reporting and higher levels of information transparency. On top of all this operational costs are too tight to carry the overhead of separate risk and assurance functions.

When the analysis is done there are 6 key lessons to learn from the global financial crisis:

  1. Integrate G, R & C.  In medium and large corporations isolated risk management practices actively work against the business.  Technical and operational experts will identify risk from experience and create risk slush-funds to mitigate them.  These increase the cost of business and in many cases price the company out of the market.  In an integrated GRC system the firm is able to manage risks across business units so that the risk funds are held centrally and do not add a premium to initial project costs.  Risk identification and analysis percolates from the bottom up but governance is driven from the top down.  In an integrated system they both to work within the business lifecycle to add the right mix of checks and balances so that no additional drag is added to investment/project approvals.
  2. Make Passive GRC Active.  Systems need to be active.  They need to hunt out risk, define it, quantify it and measure the dependencies of the risk.  Then, those same systems need to bring it to the attention of the executives so that they may make informed investment decisions.  In the end, humans follow the law of least effort:  employees will follow the path of least resistance in designing and gaining approval for their projects.   GRC must not follow a system of honour & audit but rather one of  active assurance.  When GRC systems are passive the business lifecycle becomes clogged with nugatory and useless program reviews that turn into technical sales pitches by design teams.  Such events and practices only serve to affirm the belief that GRC is a legal burden and one which only serves to satisfy the needs of regulatory compliance.  Raytheon, for instance, have an excellent system of governance-by-exception.   Their Integrated Product Design System (IPDS) has active governance measures and allows Raytheon to manage a pipeline of thousands of critical projects dynamically and by exception.GRC
  3. Get Granular.  When projects fail it is not usually because the risks have not been adequately managed.  The primary problems in risk practices are the failures of risk identification and analysis.  Managers are simply unable to deal with risks at a granular level and then weigh them up on a per project basis.   This is largely because the technical skills needed to do so are not within the standard sets of most executives (but they are within the more mathematical ones of the FS&I industry).   Where this disparity exists then businesses need to develop separate Red Teams or Assurance Teams, either from the existing PMO of from hand picked executives.
  4. Bottom Up & Top Down.  Risk management is bottom-up but governance is top-down.  The technical skills and software reliance involved in effective risk management mean that the entire practice usually percolates from the bottom of a business, upwards.  Consequently, unless it fits within a comprehensive governance framework it will be open to being gamed by senior executives.  This is why major projects which are seen as must-win are often approved with little or no governance or assurance.
  5. Risk Ownership.  Risks need to be owned at the lowest responsible level.  This is to say that when things go wrong the person at the lowest level who has the greatest amount of operational responsibility must be able to take charge to mitigate all aspects of the risk.  It is vital that the person owning the risk be able to recognise the variables which may see the risk realised.  It is also critical that the risk owner understand the corporate decision points, i.e. the points at which the contingency plans should be triggered.
  6. Invest in the Right Type of Risk Culture.  Risk should not be a dirty word.  Risks are inherent in every project and balancing them quantitatively and qualitatively is an essential skill for all senior executives.  Risk should be as much about seizing opportunity as it is about guarding profitability.  Businesses need to invest in top talent in order to drive good risk practices from the top.  Effective, Active-GRC involves a complex array of tools, practices, structures and processes which need an experienced senior executive to drive them constantly and consistently in the business.  The softer side of risk management cannot be neglected.  The nature of risk forces people onto the defensive as they attempt to justify all aspects of their project designs.  CROs need to help executives understand that all projects must balance risk if they are to attempt to push profitability.  Otherwise, risk cultures will mire companies in conservative, risk averse cultures which only act to add friction and reduce profitability.

Risk practices need to work together inside a single, comprehensive risk framework that goes beyond simple probabilistic modelling and disjointed regulatory compliance.   Businesses need to implement processes which not only integrate the business lifecycle but actively increase both liquidity and opportunity for risk to be seen to add real value to the company.   Only once this is achieved can risk management cease to be an operational drag for the business and become a value-adding proposition which works actively to increase the profit and performance of a company.

 

Building a Risk Culture is a Waste of Time 3

The focus of a good risk management practice is the building of a high-performance operational culture which is baked-in to the business.  Efforts to develop risk cultures cultures only serve to increase risk aversion in senior executives and calcify adversarial governance measures which decrease overall profitability.  The right approach to risk management is a comprehensive, holistic risk management framework which integrates tightly with the business.

risk management. waste of timeThe financial crisis is largely due to the the failure of risk management and over-exposure in leading risk-based institutions.  More specifically, the failure of risk management is linked to:

  • The failure to link link risk to investment/project approval decision making.  The aim of risk management is not to create really big risk registers.  Although, in many organisations one could be forgiven for thinking that this is the goal.  The aim of identifying risks is to calibrate them with the financial models and program plans of the projects so that risks can be comprehensively assessed within the value of the investment.  Once their financial value is quantified and their inputs and dependencies are mapped – and only then – can realistic and practical contingency planning be implemented for accurate risk management.
  • The failure to identify risks accurately and comprehensively.  Most risk toolsets and risk registers reveal a higgledy-piggledy mess of risks mixed up in a range from the strategic down to the technical.  Risks are identified differently at each level (strategic, financial, operational, technical).  Technical and Operational risks are best identified by overlapping processes of technical experts and parametric systems/discrete event simulation.  Financial risks are best identified by sensitivity analysis and stochastic simulation but strategic risks will largely focus on brand and competitor risks.  Risk identification is the most critical but most overlooked aspect of risk management.
  • The failure to use current risk toolsets in a meaningful way.  The software market is flooded with excellent risk modelling and management tools.  Risk management programs, however, are usually implemented by vendors with a “build it and they will come” mentality.  Risk management benefits investment appraisal at Board and C-Suite level and it cannot be expected to percolate from the bottom up.

RISK MANAGEMENT IS COUNTER-INTUITIVE

All this does not mean that risk management is a waste of time but rather it is counter-intuitive to the business.  It is almost impossible to ask most executives to push profits to the limit if their focus is on conservatism.  Building a culture of risk management is fraught with danger.  The result is usually a culture of risk aversion, conservatism and a heavy and burdensome governance framework that only adds friction to the business lifecycle and investment/project approval process.  Executives, unable to navigate the labyrinthine technicalities of such a systems achieve approvals for their pet programs by political means.  More so, projects that are obviously important to the business actually receive less risk attention than small projects.  Employees learn to  dismiss risk management and lose trust in senior management.

If risk management is to be an effective and value-adding component it must be a baked into the business as part of the project/investment design phase.  If not, then risk management processes  just build another silo within the business.  The key is to forget about “Risk” as the aim.  The goal must be a performance culture with an active and dynamic governance system which acts as a failsafe.  The threat of censure is the best risk incentive.

risk management. immature disciplineAWARENESS IS NOT MANAGEMENT

risk management. immature disciplineManagement has long been aware of risk but this does not always translate into true understanding of the risk implications of business decisions.  Risk policies and practices are often viewed as being parallel to business and not complimentary to it.

Why is it that most businesses rate themselves high on risk management behaviours?  This is largely because businesses do not correlate the failure of projects with the failure of risk and assurance processes. 

In a 2009 McKinsey & Co survey (published in June 2012 “Driving Value from Post-Crisis Operational Risk Management”) it was clear that risk management was seen as adding little value to the business.  Responses were collected from the financial services industry – an industry seen as the high-water mark for quantitative risk management. 

COLLABORATION IS THE KEY

Risk management needs to become a collaborative process which is tightly integrated with the business.  The key is to incentivise operational managers to make calculated risks.  As a rule of thumb there are 4 key measures to integrate risk management into the business:

  1. Red Teams.  Despite writing about collaboration the unique specialities of risk management often requires senior executives to polarise the business.  It is often easier to incentivise operational managers to maximise risks and check them by using Red Teams to minimise risks.  Where Red Teams are not cost effective then a dynamic assurance team (potentially coming from the PMO) will suffice.  Effective risk management requires different skills and backgrounds.  Using quantitative and qualitative risk management practices together requires a multi-disciplinary team of experts to suck out all the risks and calibrate them within the financial models and program schedules in order that investment committees can make sensible appraisals. 
  2. Contingency Planning.  Operational risk management should usually just boil down to good contingency planning.  Due to the unique skill sets in risk management, operational teams should largely focus on contingency planning and leave the financial calibration up to the assurance/Red teams to sweep up.
  3. Build Transparency through Common Artefacts.  The most fundamental element of a comprehensive  risk process is a lingua franca of risk  – and that language is finance.  All risk management tools need to percolate up into a financial model of a project.  This is so that the decision making process is based on a comprehensive assessment and when it comes to optimise the program the various risky components can be traced and unpicked.
  4. Deeper Assurance by the PMO.  The PMO needs to get involved in the ongoing identification of risk.  Executives try and game the governance system and the assurance team simply does not have the capacity for 100% audit and assurance.  The PMO is by far the best structure to assist in quantitative and qualitative risk identification because it already has oversight of 100% of projects and their financial controls.

Traditional risk management practices only provide broad oversight. With the added cost pressures that businesses now feel it is impossible to create large risk teams funded by a fat overhead. The future of risk management is not for companies to waste money by investing in costly and ineffective risk-culture programs.  Good risk management can only be developed by tightly integrating it with a GRC framework that actively and dynamically supports better operational performance.