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Addressing Risk Across the Enterprise: Start at the Top

Published: November 24 2008, 03:30 AM
by Christopher Fox


We are at just the beginning of challenging times ahead. Risk management is becoming of increasing importance.

For example, according to a Towers Perrin survey of finance executives at major U.S. corporations, CFOs consider "improved risk management" as the top priority right now given the current financial crisis -- even more important than access to capital.

Towers Perrin commissioned the survey by CFO Research Services, an affiliate of The Economist and CFO, to gain insights on how companies view the seriousness of the financial crisis for their businesses. According to the summary of the report:



  • Approximately 72% of respondents expressed concern about their own companies' risk management practices and ability to meet strategic plans. (Towers Perrin notes this suggests that finance executives, regardless of industry, perceive a need to invest in more effective risk identification, measurement and management procedures.)



  • More than half (55%) of the CFOs agree that they plan to put their risk management practices under a microscope and that this investigation will in many instances reach all levels of the organization, from the board down and from the shop floor up.




There is a risk that management will focus on specific risk associated with the financial crisis. We believe that risk management encompasses an entire company and the potential impact of external events on the company.

At CA we are developing a risk management library that addresses risk throughout a company. At the highest level this structure includes the following risk elements:



  • Governance



  • Operational



  • Technological



  • Compliance



  • Financial



  • Financial Reporting



  • Economic



  • Environment Regulation



  • Stakeholders



  • International



  • Market



  • Social Trends




In the coming weeks on this blog, we will look at risk management holistically and discuss risk management considerations that businesses should be addressing over the next twelve months.

We begin with the following elements of Governance risk:




  • Governance Structure: The risk of loss through legislative action or loss of reputation because an organization cannot demonstrate that it has an effective corporate governance structure




  • Organizational Structure: The risk of loss through legislative action or loss of reputation because an organization does not have an appropriate culture, including ethical culture, to support the corporate governance objectives




The ability to demonstrate that risk is being effectively managed at the board and senior management level is beginning to be raised as an issue in the media.



On November 10, 2008, Tobin Harshaw of the New York Times compiled some interesting insights regarding the A.I.G. bailout in an "Opinionator" blog post:

"Executives there are handsomely paid, yet senior management cast a blind eye as one unit earned outsized profits while taking risks that would have driven A.I.G. into bankruptcy were it not for the Fed's rescue.

"¦the biggest single job of senior management in a financial institution ought to be to assure the health and survival of the entity, which means risk management and control is top of the list. "¦ Anytime a unit starts reporting very large profits, managers should be all over it like a cheap suit to make sure the earnings are not the product of massive risk taking."


(From the Naked Capitalism blog
.)





In the NY Daily News on November 9, 2008, Carl Icahn focused on Lehman in an opinion column. He wrote:

"But behind the success or failure of every corporation is a board of directors which is supposed to monitor the CEO, set salaries and, importantly, weigh risks and business strategies.

So we must ask: Where were the directors of these companies? Were they qualified to assess the risks their companies were taking? Or were they off playing golf at Augusta or jetting to the Super Bowl aboard company aircraft?

Consider the Lehman board. Of the ten non-management directors, only three "¦ has financial industry background"¦. Moreover, its five member finance and risk committee included a theater producer, a retired naval officer, a retired computer executive and a retired television CEO. Only the chairman had a finance background. He was eighty years old.

Even if these people were qualified to evaluate the bank's risks, the committee met just twice a year in 2006 and 2007, according to the Corporate Library, a research group. Its editor, Nell Minow, told a House committee last month: "˜A company that had $7 billion in losses after becoming embroiled in the global credit crisis had a risk management committee that did not understand or manage its risk.'"



What should the board and senior management do to address these risks proactively?

The first step could be to specifically have someone monitor developments in the governance and risk management area and to raise issues proactively and suggest potential management actions. This would be especially important for potential Government regulations, but of equal importance would be the monitoring of potential law suits. This could be performed by a risk manager in conjunction with general counsel and the regulatory compliance group.

The second step could be to assess the current state of governance, risk and compliance. Future blogs in this series will address factors to be considered in this review; however the first steps could be taken quickly. As part of this review, consideration could be given to the timeliness of risk management reporting "" including escalation of important issues. I suggest that the automation of GRC could address the timeliness issue and the review should include the reporting of significant issues to board members between board meetings.

Watch our blog in coming weeks to learn more about our thoughts on managing risk across the enterprise.
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By: Christopher Fox
Chris is a Senior Principal Product Manager in CA’s GRC group. His primary responsibilities include developing thought leadership in GRC and then passing this knowledge through to our development teams to assist in product development and also to our customers. Prior to joining CA, Chris has had many...
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3 people have left comments:

I agree with the points being made in these comments. It is clearly critically important that the Board be proatively, and continuously involved in oversight of any major risk management activities within the corporation.<br><br>However, I personally feel that Board level oversight is necessary BUT NOT SUFFICIENT to prevent the type of situations that have given rise to our current crisis. Effective risk management must be done at essentially all levels of the organization, especially including formal reviews of the assessment of the risk levels of all important events or investments. Then, these risk assessments can be brought to the Board for review.<br><br>I also believe that Board involvement is very unlikely to prevent outright fraud perpetrated by a single, or a very small number, of people. For example, the <a href="en.wikipedia.org/.../Barings_Bank_collapse" rel="nofollow" rel="nofollow">Barings Bank fraud by Nick Leeson</a> would not have been caught by the Board, although it&amp;#39;s possible they might have be able to identify anomolous trading patterns that should have raised an alarm. But, then again, since those patterns didn&amp;#39;t raise an alarm at lower levels, it&amp;#39;s unlikely that the Board would have been involved in direct oversight of those activities.<br><br>Bottom Line: I agree with your opinions. But, we can&amp;#39;t use &amp;quot;Board oversight&amp;quot; as a substitute for ongoing, proactive, effective oversight at every level of the organization.

Posted by: Sumner Blount | October 1, 2009 12:03 PM

@Tejus I agree. A key assumption that is made in the risk management discussion is that a board effectively oversees the risk management process. A board should definitely meet more than every six months. In addition they need to be kept informed by the CEO of any significant or contemplated changes at a company. I also think that they need a monthly strategic profile of the company (which would not require a formal meeting) including progress towards strategic goals and changes in the risk profile. Any changes outside a preset boundary level should also be flagged for attention.

Posted by: Christopher Fox | October 1, 2009 12:03 PM

You are absolutely spot on when you blame risk management or the lack thereof as one of the primary reasons behind the financial crisis that we are facing today. But you have to realize the final checkpoint is Board level oversight. If the Board of a public company is engaged and active, the probability of such incidents of financial impropriety, is very low. But if directors have accepted multiple Board positions with an unusually large number of public companies, the much needed oversight is absent. Take the case of Sir Winfried Bischoff of Citigroup. He is on atleast 4 other Boards of public companies. How can a shareholder expect attention and focus from such a busy individual?

Posted by: Tejus Trivedi | October 1, 2009 12:03 PM

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