Canadian Annual Derivatives Conference of the Montréal exchange Characteristics of Superior Risk Management Solutions Fairmont Le Chateau Frontenac Quebec, Canada Friday, August 19, 2005 9:40 am – 10:20 am Dr. Robert M. Mark Bmark.blackdiamond@tmo.blackberry.net 925 299 6859 Dr Bob Mark 1 A significant challenge is to stay on top of a complex combination of “Characteristics” which are at the “Core of Superior ERM Solutions” The ability to efficiently integrate all the components of risk on a *portfolio basis as well as to effectively operate in complex *markets *Customers Investors while serving *customers as well as satisfying *regulators is a direct function of the quality of the policies, methodologies and *Regulators infrastructure Financial Risk -Market Risk -Credit Risk Non Financial Risk -Operational Risk -Business Risk Rating Agencies Equity Analysts *Markets Methodologies Dr Bob Mark 2 Basel has driven a significant spend on risk management Three Basic Pillars Minimum Capital Requirement Supervisory Review Process Dr Bob Mark Market Discipline Requirements 3 The ability to proactively manage risk on an integrated portfolio mgmt* basis: -stems from having several sophisticated layers of functionality . -is based on a relentless commitment toward superior analytics and infrastructure = Portfolio Mgmt + Performance Measurement + Facilitate Pricing Manage + Accounting Capital Reserves + Economic (Risk) Capital and Capital + Regulatory Capital (Basel) + Stress Test & Scenario Analysis Risk Analysis + Value at Risk + Monitor Identify & Avoid Limit Management Superior ERM Solutions Dr Bob Mark 4 Example 1: The Credit Portfolio Management Group(CPMG) proactively manages credit risk on an integrated* basis Capital and Risk Committee • I S S U E R S & B O R R O W E R S Client Coverage Policy setting Limit setting Risk reporting Syndication / Distribution Origination/ Underwriting CPMG Risk Evaluation Asset Sales & Trading Quantification of risk (EL, capital) Model selection/ Validation Product Structuring/ Securitization Monitoring & Review B A N K S & I N V E S T O R S Servicing Dr Bob Mark 5 A significant challenge is to build a “Superior ERM Solution” in partnership with the C Suite whose “Characteristics” can be benchmarked in terms of: Dr Bob Mark 6 Characteristics of Policies at the Core of Superior ERM Solutions These include: The tolerance for risk (financial and non financial) is integrated and consistent with the Business Strategies (and visa versa) Risk measures are backtested, authorities are expressed in meaningful terms and reflect a desired tolerance for risk Independent Superior ERM Solutions Risk is properly disclosed (e.g. Chinese walls may exist) internally and externally on a drill down and integrated portfolio management * basis Dr Bob Mark 7 Risk Disclosure Key characteristics of disclosure include having the ability to provide disclosures such as: Slicing and dicing the risk in real time (or near real time) by risk type, asset class ,business, product, industry, country, etc mark-to-market (mark- tomodel) vs. cash flow views GAAP Independent Superior ERM Solutions vs. Economic view Capital (e.g. GAAP Capital vs. Economic Capital vs. Basel Capital) the main drivers of risk Dr Bob Mark 8 Disclosing the main drivers of financial and non financial risk would include answering such questions as : What are the top risks in the trading book and banking book (i.e. a literal hit parade of risks) Where are the concentrations of risk (e.g. hot spots) How often the list of main risks change Have the forecasts of the top financial and operational risks (e.g. stress tests) been predictive? Have any of the top risks listed caused management to take action to alter them in any way? If so, how? What financial risks keep management up late at night? Dr Bob Mark 9 Example 2: August 1998: Equity prices dropped sharply Equity Volatility increased Liquidity dried up (Flight to quality) August ‘98 High Volatility Correlations broke down Credit spreads widened Credit quality deteriorated Wide Credit Spread Low Liquidity Dr Bob Mark 10 Example 3 :Certain types of backtesting disclosure have become standard (e.g. market risk).Ultimately,similar disclosure will become standard across all risk types ALCO Limit - Upper Boundary Daily Net Trading Revenue C$ Millions Potential Predicted Positive Revenue ALCO Limit - Lower Boundary Potential Negative Revenue Predicted August 27, 1998 Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Dr Bob Mark 11 Characteristics of Methodologies at the Core of Superior ERM Solutions These include: VaR and Stress Test methodologies are predictive of the actual losses and integrated across all risks and all books of business Ongoing dedication toward first class risk methodology research Mathematical models are properly vetted. Positions are properly valued (and becomes a bigger deal with SOX). Risk methodologies are tied into pricing and performance measurement. Independent First-Class Proactive Risk Management Dr Bob Mark 12 Example 4: A key characteristic of superior market risk methodologies is to realistically capture liquidity risk Positions Scenarios Trading Rules Initial Position Data Scenarios Data Change in Positions Hedging Horizon Volatility Price Path Impact on Liquidity Dynamic Adjustments of The Greeks Positions Adjust Over Time Market Movements Over Time P&L Results Dr Bob Mark 13 Example 5:A key characteristic of superior credit risk solutions is to build a robust Risk Rating Process that enables you to calculate the PD, LGD ,attribute capital and price credits Collateral Transaction Structure Maturity of Transaction Facility Rating Third Party Support Managerial Capability,Competitive Position Quality of Financial Information, Country Risk Financial Assessment (Floor on obligor rating) Dr Bob Mark Obligor Rating 14 A term structure of risk is calculated over multiple time periods The term structure of PD’s (from the obligor rating) and RR’s (from the facility rating ) is typically applied to price as well as determine the capital for credit risk EXAMPLE PROBABILITY EXPOSURE DEFAULTS 0 tN t0 RECOVERIES Dr Bob Mark 15 Credit risk models (eg Merton’s model) have also become deeply practical for the purposes of predicting such things as: Probability of default (PD) Assets Value VT V0 exp m 22 T TZ T Distribution of asset values at maturity of the debt obligation E(VT)=VOemT VT V0 F Probability of default T Dr Bob Mark Time 16 Example 6: A key characteristic of superior credit risk stress test solutions is to arrive at reasonable paranoia stress tests Stressing the boundaries of credit risk EXAMPLE Shocks EXPOSURE DEFAULTS . . .To produce perturbations of combined distributions of simulated future credit losses PROBABILITY Credit risk factors may be shocked . . . 0 RECOVERIES Dr Bob Mark tN t0 17 Example 7:A key characteristic of being able to calculate credit risk is to be able to calculate a joint PDF for such things as credit grade migration… Obligor #2 (single-A) Obligor #1 AAA AA A BBB BB B CCC Default BB AAA AA A BBB BB B 0.03 0.14 0.67 7.73 80.53 8.84 1.00 1.06 0.09 0.00 0.00 0.00 0.01 0.07 0.01 0.00 0.00 2.27 0.00 0.00 0.02 0.18 1.83 0.20 0.02 0.02 91.05 0.03 0.13 0.61 7.04 73.32 8.05 0.91 0.97 5.52 0.00 0.01 0.40 0.43 4.45 0.49 0.06 0.06 0.74 0.00 0.00 0.00 0.06 0.60 0.07 0.01 0.01 0.26 0.00 0.00 0.00 0.02 0.20 0.02 0.00 0.00 CCC Default 0.01 0.00 0.00 0.00 0.00 0.01 0.00 0.00 0.00 0.06 0.00 0.00 0.00 0.00 0.05 0.00 0.00 0.00 Joint migration probabilities (%) with zero correlation for 2 issuers rated BB and A Dr Bob Mark 18 ….which includes being able to calculate meaningful estimates of correlation between asset returns -Typical assumption is that the joint normalized return distribution for the assets is a bivariate normal PDF 1 2 2 f rBB , rA ; exp rBB 2 rBB rA rA 2 2 1 2 2(1 ) 1 Note: Equity returns are sometimes used as a proxy for asset returns. Dr Bob Mark 19 Example 8: A key characteristic of superior methodologies is that they are used to price market, credit and operational risk. For example, a Credit Derivative can be modeled as a put l P = - N (- d - rt )1 V0 + Fe N (- d 2 ) l where P is the current value of the put, N(.) is the cumulative standard normal distribution, and - rT 1 s 2 + + s + ln(V0 / F) (r 2 )T ln(V0 / Fe ) 2 T = d1 = S T S T 1 2 d 2 = d1 - s T Dr Bob Mark l 20 …and can be used to calculate expected credit spreads (CS). Liquidity is a key element - B0 Fe rT - P ln ln F = F yT = T T csT = yT - r csT = yT - r = - 1 V0 + [ ln N (d 2 ) - rT N ( d1 )] T Fe Dr Bob Mark 21 The Credit Insurance market has exploded Global Credit Derivatives Volume now over 5 trillion US$ ($ in billions) 5,000+ 5,000 4,000 3,000 3,000 2,097 2,000 1,009 1,000 1,280 668 180 350 1997 Sources: 1998 1999 2000 2001 2002 Mar-03 British Bankers Association 2001-2002 Credit Derivatives Survey and Standard and Poor’s Financial Institutions: Demystifying Banks’ Use of Credit Derivatives Dr Bob Mark (December 8, 2003) 2004E 22 Percent of Accounts Example9: A key characteristic of superior retail methodologies is that credit scoring analytics can be supplemented with sophisticated analytics….. Cut-off Score Good Accounts Bad Accounts Credit Score The presumption underlying credit scoring models is that there exists a metric that can divide good credits and bad credits into distinct distributions Dr Bob Mark 23 ….. which can be used to construct an efficient frontier so as to optimally make market share vs. risk tradeoff decisions Low cutoffs E [ Volume ] high High cutoffs low Dr Bob Mark high 24 Significant progress has been made in measuring market risk and credit risk …. with some early success at measuring operational risk but… having a a highly reliable unified measure of risk inside of a common risk architecture is at the core of superior ERM solutions Dr Bob Mark 25 Valuation and Performance Key Characteristics includes an ability to : Independent accurately vet and value transactions (e.g. loan valuations and derivative valuations) Superior ERM Solutions appropriately (e.g. traditional RAROC is flawed) quantify the return to risk relationships of the individual as well as portfolio of transactions Dr Bob Mark 26 Example 10:A key characteristic of superior solutions is that all models to measure risk are fully vetted Input Risk Estimation Risk Model Risk (valuation) Deal Database Market Database Statistical Tools Model 1 Vendors of parameters Model n Model N Model Calibration Deal Valuation Hedging Risk Hedging Models Dr Bob Mark 27 Key Characteristics of Infrastructure at the Core of Superior ERM Solutions includes having: The appropriate people in place A single enterprise wide risk and data architecture A integrated risk architecture which incorporates and replaces many of the mid office functions (e.g. valuing deals) Single Independent Superior ERM Solutions integrated risk engine Real time access to data (e.g. market data,transaction data,legal data,etc) Periodic Change initiatives Dr Bob Mark 28 Building the infrastructure to support an Independent and Integrated Comprehensive ERM integrated framework is Operational Risk Business Risk Incremental Risk Total Risk Dr Bob Mark Price Deal Risks Manage Business Unit Risk Market Risk Confirm/ Settle Credit Risk Execute Framework Compare Risk to Limit tough ,efficient (e.g. replaces mid office costs) and effective (e.g. for direct risk takers) and has become a competitive necessity Analyze Deal 29 Appendix Operational Risk Matrix (Basel II) Dr Bob Mark 30 Appendix Basel II Level 2. Operational Risk Loss Event Classification to Level 3. Event Type, (7) 1. Internal Fraud 2. External Fraud 3. Employment Practices & Workplace Safety Categories (Level 2) Definitions Losses due to acts of a type intended to defraud, misappropriate property or circumvent relations, the law or company policy , excluding diversity/discrimination events, which involves at 1. A. Unauthorized Activity least one internal party 1.B. Theft & Fraud Losses due to acts of a type intended to defraud, misappropriate property or circumvent the law, by a 2.A. Theft & Fraud third party 2.B. Systems Security Losses arising from acts inconsistent with employment, health or safety laws or agreements, from payment of personal injury claims, or from 3.A. Employee Relations diversity/discrimination events 3.B. Safe Environment 3.C. Diversity & Discrimination Dr Bob Mark Insurance Coverage Available Activity (Some Examples Only - Not Comprehensive) (Level 3) Yes 1.A.1. Transactions not reported, (intentional), 1.A.2. Transaction type unauthorized, (w/$ loss) 1.A.3. Mismarking of position, (intentional), 1.A.4. Frontrunning, Yes 1.B.1. Fraud, 1.B.2. Credit fraud, 1.B.3. Worthless deposits, 1.B.4. Theft, 1.B.5. Extortion, 1.B.6. Embezzlement, 1.B.7. Robbery, 1.B.8. Misappropriation of assets, 1.B.9. Malicious destruction of assets, 1.B.10. Forgery, 1.B.11. Check kiting, 1.B.12. Smuggling, 1.B.13. Account take over/impersonation, 1.B.14. Tax noncompliance/willful evasion, 1.B.15. Bribes, 1.B.16. Kickbacks, 1.B.17. Insider Trading Yes 2.A.1. Theft/Robbery, 2.A.2. Forgery, 2.A.3. Check Kiting 2.B.1. Hacking Damage, 2.B.2. Theft of Information, (w/& loss) No 3.A.1. Compensation, 3.A.2. Benefit, 3.A.3. Termination issues, 3.A.4. Organized labor activity Yes 3.B.1. General Liability, 3.B.2. Employee health & safety rules events, 3.B.3. Workers Compensation Yes 3.C.1. All discrimination types Yes 31 Appendix Basel II Level 2. Operational Risk Loss Event Classification to Level 3. Event Type, (7) Definitions Insurance Coverage Available Activity (Some Examples Only - Not Comprehensive) (Level 3) Yes 4.A.1. Fiduciary breaches/guideline violations, 4.A.2. Suitability/disclosure issues, (KYC, etc.), 4.A.3. Retail customer disclosure violations, 4.A.4. Breach of privacy, 4.A.5. Aggressive sales, 4.A.6. Account churning, 4.A.7. Misuse of confidential information, 4.A.8. Lender Liability 4.B. Improper Business or Market Practices No 4.B.1. Antitrust, 4.B.2. Improperly trade/market practices, 4.B.3. Market manipulation, 4.B.4. Insider trading on a firm's account, 4.B.5. Unlicensed activity, 4.B.6. Money Laundering 4.C. Product Flaws No 4.C.1. Product defects, (unauthorized, etc.), 4.C.2. Model Errors No 4.D.1. Failure to investigate client per guidelines, 4.D.2. Exceeding client exposure limits No 4.E.1. Disputes over performance of advisory activities Yes 5.A.1. Natural disaster losses, 5.A.2. Human losses from external sources, (terrorism, vandalism) Categories (Level 2) Losses arising from an unintentional or negligent failure to meet a professional obligation to specific 4. Clients, clients, (including fiduciary and suitability Products & requirements), or from the nature or design of a 4.A. Suitability, Disclosure & Fiduciary Business Practices product 4.D. Selection, Sponsorship & Exposure 4.E. Advisory Activities 5. Damage to Physical Assets Losses arising from loss or damage to physical assets from natural disaster or other events 5.A. Disasters & other events Dr Bob Mark 32 Appendix Basel II Level 2. Operational Risk Loss Event Classification to Level 3. Event Type, (7) 6. Business disruption & System Failures Definitions Categories (Level 2) Insurance Coverage Available Activity (Some Examples Only - Not Comprehensive) (Level 3) Yes 6.A.1. Hardware, 6.A.2. Software, 6.A.3. Telecommunications, 6.A.4. Utility outage/disruptions No 7.A.1. Miscommunication, 7.A.2. Data Entry maintenance or loading error, 7.A.3. Missed deadline or responsibility, 7.A.4. Model/system misoperation, 7.A.5. Accounting Error/entity attribution error, 7.A.6. Other task misperformance, 7.A.7. Delivery failure, 7.A.8. Collateral management failure, 7.A.9. Reference Data Maintenance No 7.B.1. Failed mandatory reporting obligation, 7.B.2. Inaccurate external report, (loss incurred) No 7.C.1. Client permissions/disclaimers missing, 7.C.2. Legal documents missing/incomplete Yes 7.D.1. Unapproved access given to accounts, 7.D.2. Incorrect client records, (loss incurred), 7.D.3. Negligent loss or damage of client assets 7.E. Trade Counterparties No 7.E.1. Non-client counterparty misperformance,7.E.2. Misc. non-client counterparty disputes 7.F. Vendors & Suppliers No 7.F.1. Outsourcing, 7.F.2. Vendor disputes Losses arising from disruption of business or system failures 6.A. Systems 7. Execution, Losses from failed transaction processing or process 7.A. Transaction Delivery & Process management, from relations with trade Capture, Execution & Management Counterparties and vendors Maintenance 7.B. Monitoring & Reporting 7.C. Customer Intake & Documentation 7.D. Customer/client Account Management Dr Bob Mark 33 ANNOUNCING Risk Management Michel Crouhy, Dan Galai, and Robert Mark Crouhy,Galai and Mark Co-Authored a leading Risk Management Book. This Book is considered the Risk Management benchmark for technical and practical Risk Management strategies. The All-in-One Banker's and Financial Manager's Guide for Implementing and Using an Effective Risk Management Program In today’s world of multibillion-dollar credit losses and bailouts, it has become increasingly imperative for corporate and banking leaders to monitor and manage riskon all fronts. Risk Management introduces and explores the latest financial and hedging techniques in use around the world, and provides the foundation for creating an integrated, consistent, and effective risk management strategy. Risk Management presents a straightforward, nononsense examination of the modern risk management function — and is today’s best risk management resource for bankers and financial managers. Its tested and comprehensive analyses and insights will give you all the information you need for: Risk Management Overview — From the history of risk management to the new regulatory and trading environment, a look at risk management past and present 700 pages ISBN: 0-07-135731-9 $70.00 Risk Management Program Design — Techniques to organize the risk management function, and design a system to cover your organization’s many risk exposures Risk Management Implementation — How to use the myriad systems and productsvalue at risk (VaR), stress-testing, derivatives, and morefor measuring and hedging risk in today’s marketplace To Order Call: 1-800-2-MCGRAW In the financial world, the need for a dedicated risk management framework is a relatively recent phenomenon. But as the recent crises attest, lack of up-todate knowledge concerning its many components can be devastating. For financial managers in both the banking and business environments, Risk Management will introduce and illustrate the many aspects of modern risk managementand strengthen every financial risk management program. Fax Orders to: 1-614-755-5645 Dr Bob Mark 34 Bio of Dr. Mark Dr. Robert M. Mark is the Chief Executive Officer of Black Diamond which provides corporate governance, risk management consulting and transaction services. He serves on several Boards such as the Fields Institute for Research in Mathematical Sciences, IBM’s Deep Computing Institute, Checkpoint Canada, The Royal Conservatory and is an Advisory Director on Entergy Koch’s Audit Committee of the Board . He also serves on Checkpoint’s Investment Committee. In 1998, he was awarded the Financial Risk Manager of the Year by the Global Association of Risk Professionals (GARP). He is the Chairperson of The Professional Risk Managers’ International Association’s (PRMIA) Blue Ribbon Panel Prior to his current position, he was the Senior Executive Vice-President and Chief Risk Officer (CRO) at the Canadian Imperial Bank of Commerce (CIBC). Dr. Mark was a member of the Management Committee. Dr. Mark’s global responsibility covered all credit, market and operating risks for all of CIBC as well as for its subsidiaries. Prior to his CRO position, he was the Corporate Treasurer at CIBC. Prior to CIBC, he was the partner in charge of the Financial Risk Management Consulting practice at Coopers & Lybrand(C&L). The Risk Management Practice and C&L advised clients on risk management issues and was directed toward financial institutions and multi-national corporations. This specialty area also coordinated the delivery of the firm’s accounting, tax, control, and litigation services to provide clients with integrated and comprehensive risk management solutions and opportunities. Prior to his position at C&L, he was a managing director in the Asia, Europe, and Capital Markets Group (AECM) at Chemical Bank. His responsibilities within AECM encompassed risk management, asset/liability management, research (quantitative analysis), strategic planning and analytical systems. He served on the Senior Credit Committee of the Bank. Before he joined Chemical Bank, he was a senior officer at Marine Midland Bank/Hong KongShanghaiBank (HKSB) where he headed the technical analysis trading group within the Capital Markets Sector. He earned his Ph.D., with a dissertation in options pricing, from New York University’s Graduate School of Engineering and Science, graduating first in his class. Subsequently, he received an Advanced Professional Certificate (APC) in accounting from NYU’s Stern Graduate School of Business, and is a graduate of the Harvard Business School Advanced Management Program. He is an Adjunct Professor and co-author of “Risk Management” (McGraw-Hill), published in October 2000. He also served on the board of ISDA as well as the Chairperson of the National Asset/Liability Management Association (NALMA). Dr Bob Mark 35