Operational risk is fundamentally different from all other risks taken on by a bank. It is embedded in every activity and product of an institution, and in contrast to the conventional financial risks (e.g. market, credit) is harder to measure and model, and not straight forwardly eliminated through simple adjustments like selling off a position. Operational risk tends to be about 9-13% of the total risk pie, though growing rapidly since the 2008-09 crisis. It tends to be more fat-tailed than other risks, and the data are poorer. As a result, models are fragile -small changes in the data have dramatic impacts on modeled output -and thus required operational risk capital is unstable. Yet the regulatory capital regime is, surprisingly, more rigidly model focused for this risk than for any other, at least in the U.S. We are especially concerned with the absence of incentives to invest in and improve business control processes through the granting of regulatory capital relief. We make four, not mutually exclusive policy suggestions. First, address model fragility through anchoring of key model parameters, yet allow each bank to scale capital to their data using robust methodologies. Second, relax the current tight linkage between statistical model output and required regulatory capital, incentivizing prudent risk management through joint use of scenarios and control factors in addition to data-based statistical models in setting regulatory capital. Third, provide allowance for real risk transfer through an insurance credit to capital, encouraging more effective risk sharing through future product innovation. Fourth, expand upon the standard taxonomy of event type and business line to include additional explanatory variables (such as product type, flags for litigated events, etc.) that would allow more effective interbank sharing and learning from experience. Until our understanding of operational risks increases, required regulatory capital should be based on methodologies that are simpler, more standardized, more stable and more robust. (Corresponding author: til.schuermann@oliverwyman.com). Professor Scott's participation in this project was supported under his general consulting relationship with State Street Corporation. We would like to thank Eduardo Canabarro, Misha Dobrolioubov, Ramy Farha, John Jordan, Andy Kuritzkes and Daniel Mikkelsen for helpful comments and discussion. All remaining errors are ours, of course.
This paper recounts some well-known problems confronting European monetary union (EMU), such as withstanding asymmetric shocks and maintaining domestic political support. It then examines how a speculative attack could damage a target country's banking system, and how the basic structure of EMU could facilitate its break-up. On the basis of this analysis, one might reasonably conclude that there is a significant chance -over one in ten -that EMU may break up in whole or in part.The paper then focuses primarily on two significant problems related to a break-up. First, a country seeking to leave EMU, particularly after the transition period, may have difficulty re-establishing its national currency unilaterally, as its economy is likely to have become thoroughly 'euroized'. Second, any break-up accompanied by re-denomination of existing euro obligations, including government bonds, will create great legal uncertainty and costly litigation. There are no continuity of contract rules for exiting EMU equivalent to those for entering. Both problems require cooperative and deliberative solutions and will be difficult and costly to solve. If such problems are properly taken into account, which has not previously been the case, a euro break-up in the foreseeable future, particularly after transition, is considerably less likely than the above estimate of one in ten.
This chapter addresses the issue of whether and to what extent banks should be required by regulation to hold capital against operational risks. It argues that the types of operational risk for which Basel II requires capital, internal or external event risks, are and should be dealt with by other means — better controls, loss provisions, or insurance. Basel's definition of “operational risk” excludes the major category of non-financial risk for which banks do hold capital — namely, business risk. It is estimated that business risk accounts for slightly more than half of a bank's total non-financial risk, which, in turn, averages about 25 to 30% of economic capital. Analysing legal risk, as a type of operational risk, the chapter shows the difficulties in defining or predicting such risk, and that the amount of such risk will vary depending on the legal jurisdictions to which a bank is subject. It also argues that the Basel II limit of 20% on capital mitigation achievable through insurance is arbitrary and creates a perverse incentive for banks to be underinsured. It generally concludes that banks should not be required by regulation to hold capital for operational risks; the issue would be better dealt with through supervision and market discipline.
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