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2nd International Conference on Operational Risk Sao Paulo, Brazil, June 5, 2009 Tsuyoshi Nagafuji Financial Services Agency, Japan
This presentation does not necessarily express established views or policies of the FSA.
Overview : Objective
Sharing my experience in validating and approving Japanese banks AMA applications. Presenting what we have done or what we are actually doing in Japan, rather than what we hope to do. Focusing on the factors that remain until the final stage for application, which banks find difficult and time consuming to address. 9 Model sensitivity analysis / stress testing: Do you know all the possibilities for strange behavior? 9 Scenarios rules and documentation: Have you done your best to exclude subjectivity? 9 Use test: Are you actually using the framework? Is it really working?
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Overview : Method
I am using a realistic model of AMA models" as an example, in consideration of anonymity. I am using The model of AMA models that I presented at the Operational Risk Scenario Analysis Workshop held at Bank of Japan, the central bank, in 2006*.
* The model presented here is the same as the one I presented in 2006, but the description is simplified. Please see Quantification of Operational Risk Using Scenario Data (Nagafuji, 2006) for the details.
The model is extremely simplified but still retains some aspects of typical AMA models used by Japanese banks. 9 The model is based on real internal data and real scenario data from major Japanese banks. 9 The model has a similar structure to typical Japanese models.
Overview : Outline
Presentation Overview (5 minutes) 1. Context (5 minutes) 2. Sample Model (10 minutes) 3. Validation of the Sample Model (15 minutes) Concluding Remarks (5 minutes) Q & A (5 minutes) (Total: 45 minutes)
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( $82 bil)
Mizuho 6 15
($49 bil)
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SMFG ($44
28 38 48 50 66
co
81 89 94
co u Ita es an
Br ad
Top 20 Banks
<Japanese banks> 98 banks in the Top 1,000 list.
Top 21 100
<Brazilian banks> 14 banks in the Top 1,000 list.
ni b
(Now merged)
BB
Loss frequencies
(# of losses greater or equal to $20,000, per year, per total assets of $1 billion)
About
1/40
0.03
About
1/20
1 1.5 2
0.02
* Both figures are medians of the banks that participated in the exercise (Source) 2004 U.S. LDCE, 2007 Japan LDCE (See Appendix: References about Japanese AMA implementation" for detail).
1. Preparation
Banks are encouraged to develop their framework to a practical level and use it for their internal purposes before going into the parallel run.
Ready?
OK?
3. Approval
Banks that do not meet the requirement stay at stage 2 or go back to stage 1.
3. Approval
Currently one banking group has been approved for the AMA.
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Bank X
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Bank X
Each data point is assumed to have a frequency of once in 10 years, because the observation period is 10 years
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2) Common scenarios:
Scenarios that could hit all banks at the same time: earthquakes and inter-bank settlement system failures. Each banks scenarios are aggregated to a single scenario and then put into the model.
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12 Failure in the accounts transfer system, including interruption of the accounting system 38 Failure in bond settlement (overseas), improper identity verification, error in cash transfer, etc 129
<b> Made-up scenarios for banks that did not have scenarios are also used. Some scenarios from <a> scaled by the total assets of each bank. 16
99% 23%
99.9% 34%
EL 7%
(BIA) (100%)
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Risk Amount
Scenarios
BEICFs*
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Scenarios are estimated as individual data points. Number of scenarios are large.
9 9
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Internal Losses
(1) Model
Risk Amount
BEICFs
Rules and documentations: Have you done your best to exclude subjectivity?
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As long as assumptions in the model are clarified and accounted for, this factor is not a decisive one.
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1) 2)
3 / 1,000,000
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As it is impossible and inappropriate to press one specific view, this factor has not been a decisive one at the last stage.
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Scenarios
BEICFs
The bank sets the frequency of scenarios based on the RCSA scores (ex. How effective are controls?).
The bank sets up a rule in judging whether a particular event can happen to it. 25
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.Plan
2. Do
Risk reduction measures Introducing double checking Computerize operations Restricting operations
Model/ Risk
3. See Verify the results using the model. 28
Understanding by management and business units is essential. Thus, it often becomes a determining factor at the final stage. When the AMA framework does not meet the use test requirement, it needs modification. When the modification is drastic, banks are required to take the use test again, which needs at least half a year to complete.
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Questions?
For further questions, feel free to contact:
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