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ENTERPRISE RISK MANAGEMENT: AN OVERVIEW
Enterprise Risk Management is a method for identifying, assessing, controlling, and
reporting risk throughout the enterprise
The board and management have responsibilities for governing the bank’s structure,
operations, and risks, especially by establishing a risk culture and risk appetite
Enterprise risk management typically engages three separate, independent functions
(commonly referred to as the three lines of defense: front line business units
(sometimes called risk control), independent risk management, and internal audit
ERM Requirements for Financial Institutions $50 Billion and Larger are not discussed in
this presentation – those requirements are reflected in the source materials on the last
slide of this presentation
WHAT IS ENTERPRISE RISK MANAGEMENT (ERM)?
ERM is a process by which a regulated financial institution:
Establishes a risk culture for the enterprise and a risk appetite for the businesses and
processes in which it engages;
Identifies the risks associated with those businesses and processes
Controls the risk associated with those businesses and processes
Monitors its businesses and processes to determine if the controls are effective at
preventing and detecting the risks associated with the businesses and processes
Reports to the board and management on key indicators of those risks and the effect on
the financial performance, safety, and reputation of the financial institution
ERM AND THE FEDERAL RESERVE’S SR 16-11
The Federal Reserve places significant supervisory emphasis on an institution’s
management of risk, including its system of internal controls, when evaluating the
overall effectiveness of an institution’s risk management
An institution’s failure to establish a management structure that adequately
identifies, measures, monitors, and controls the risks of its activities has long been
considered unsafe-and-unsound conduct
Principles of sound management should apply to all risks facing an institution
including credit, market, liquidity, operational, compliance, and legal risk
SR 16-11 Supervisory Guidance for Assessing Risk Management at Supervised Institutions with
Total Consolidated Assets Less than $50 Billion
ERM IS IMPORTANT FOR SUPERVISORY RATINGS
Besides limiting credit and operating losses, effective ERM affects the CAMELS
rating
The “M” in CAMELS represents an assessment of the quality of board oversight and
management supervision
The “management” rating reflects examiner conclusions about the board and
management’s willingness and ability to effectively address governance, risk
management, compliance, bank operations, and financial performance.
THE BOARD AND MANAGEMENT ARE
RESPONSIBLE FOR EFFECTIVE ERM
The board and senior management are expected to use good corporate governance
and risk governance practices to:
Set the bank’s strategy, objectives, and risk appetite
Establish the bank’s risk governance framework
Identify, measure, monitor, and control risks
Supervise and manage the bank’s business
Protect the interests of depositors, protect shareholders’ or members’ (in the case of a
mutual FSA) obligations, and take into account the interests of other stakeholders
Align corporate culture, activities, and behaviors with the expectation that the bank will
operate in a safe and sound manner, operate with integrity, and comply with applicable
laws and regulations
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