On the Gutting of Financial Services Reform « naked capitalism

There is a literature on how best to regulate systems in the face of such Knightian uncertainty. It suggests some guideposts for regulation of financial systems. First, keep it simple. Complex control of a complex system is a recipe for confusion at best, catastrophe at worst. Complex control adds, not subtracts, from the Knightian uncertainty problem. The US constitution is four pages long. The recently-tabled Dodd Bill on US financial sector reform is 1,336 pages long. Which do you imagine will have the more lasting impact on behaviour?

Second, faced with uncertainty, the best approach is often to choose a strategy which avoids the extreme tails of the distribution. Technically, economists call this a “minimax” strategy – minimising the likelihood of the worst outcome. Paranoia can sometimes be an optimal strategy….

Third, simple, loss-minimising strategies are often best achieved through what economists call “mechanism design” and what non-economists call “structural reform”. In essence, this means acting on the underlying organisational form of the system, rather than through the participants operating within it. In the words of economist John Kay, it is about regulating structure not behaviour…

I personally sympathize with simpler controls for the banking industry.

BCBS revising sound practices for operational risk management - First thought

BCBS is revising its 2003 'Sound Practices for Management and Supervision of Operational Risk'. The consultative paper for the new version was published a few days ago.

One of the first point I noted in the 2010 consultative paper is the more prominent and hands-on roles of Board of Directors. While the 2003 paper outlines the key roles of BOD as:
  • be aware of major aspects of the bank's operational risks
  • periodically review and approve the bank's operational risk management framework
  • ensure the framework is subjected to effective, independent review
The 2010 consultative paper list as the first principle that the Board of Directors should establish "tone at the top" and strong risk management culture throughout the whole business. The document also explicitly calls for BOD to review and approve risk appetite and tolerance statement, although this is usually the case anyway.

The emphasis on governance is also highlighted with the refined role of senior management who, to quote:

should develop for approval by the board of directors a clear, effective and robust governance structure with well defined, transparent and consistent lines of responsibility.

It is clear from recent events that management of operational risk cannot be left to middle management alone, without real transparency nor consistency across the organization. The revised sound practices paper also enhanced and clarified many of its principles, and reflect both recent events and the industry's responses to the risk environment that faces banks in 201X.

BCBS - Sound practices for backtesting counterparty credit risk models

Click here to download:
bcbs185.pdf (617 KB)
(download)

"This document sets out the principle terminology used in IMM
backtesting, discusses backtesting and presents examples of IMM
backtesting good practice. Given the intimate relationship between
backtesting and validation, this document also lays out other sound
practices that banks should consider in conjunction with backtesting."

IMM are banks which have been approved to use internal model to
estimate counterparty credit risk capital.