Chong Y.Y. Investment Risk Management

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168 Investment Risk Management

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Risk

numbers

General

summary

YES

Traffic light

risk areas

Risk limit

breaches

Figure 10.3 What information is included in the Board report?

changes, but risk management gives us a safety buffer. Everyone is trying to move ahead of the

investment pack. Given so much ego and PR, there is a crying need to compare performance.

There are various forms of benchmark, e.g. against the previous year’s performance, whole

industry or the top rival in the sector, etc.

Benchmarks are used to handle trickier points of detecting operational risk within a company.

Fine corporate PR and good-looking ﬁnancial statements could have been ripped apart by

organic risk red ﬂags. One of the problems may be that the risk management reports sent to

the board do not have the right information, a suitable format to understand, or the board may

not have the skills to understand. See Figure 10.3.

We have already detailed the Barings, Enron–Andersen, Worldcom incidents of the ships

that sank. What can we say of the boats that stay aﬂoat? MCI ﬂoats on, after its previous

incarnation, WorldCom, sank.

CASE STUDY: WORLDCOM

There can be fewer corporate PR campaigns that have inculcated a greater unfounded sense

of security or value than at WorldCom. The opening of holes in the company accounts

eventually led the SEC to charge the WorldCom board with committing a $3.8 billion

fraud. SEC sought ﬁnancial punishment of directors, while prohibiting destruction of case

documents and evidence (see: Whistle-blowing).

SEC alleged that WorldCom fraudulently overstated its income and falsely portrayed

itself as a proﬁtable business. WorldCom did so by capitalising expenses of $3.8 billion of

its costs, added to capital accounts in violation of generally accepted accounting principles

(GAAP).

Some of these bizarre book-keeping techniques are analogous to a householder counting

gas, utility and repair bills as income. These misled investors and manipulated WorldCom’s

earnings to keep them in line with estimates by Wall Street analysts. The fraud came from

the inside, ably assisted by the ﬁnancial experts on the Street.

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Future-Prooﬁng Against Risk 169

The SEC charged WorldCom with violating various anti-fraud legislation in June 2002.

The court orders sought against WorldCom prohibited it and its directors from destroying

valuable evidence and relevant case documents. The IT records cannot be destroyed if the

investigation is to have a good chance of success. All incriminating email letters should be

able to be tracked down or reconstituted.

WorldCom funds were frozen, especially more generous payments to its directors or

employees that might have been enjoined to destroy evidence. Regulators have to protect

the data, whistle-blowers and then hunt for the key culprits.

What we need to do is to examine the living corpse that is the company CEO before they

cause damage. This process may reduce or even prevent ﬁnancial losses that have caused major

shareholder grief in recent years. We have to conduct an adequate due diligence before the

company falls apart with us locked into the investment. Part of this process comes under the

investigation comprising forensic accounting.

Forensic accounting

Forensic accounting is a potentially rich source of value-added in ﬁnancial environments. Part

of forensic accountancy is an art, part science and the rest is detective work. There are three

ways in which it can provide a valuable service in organisations:

1. Investigate a case post facto to see where a loss has occurred within the investment environ-

ment; sniff out the cause or possible rats, then set up the enquiry for full regulatory/judicial

process and compensation/redress where possible.

2. Examine a business to spot current areas of weaknesses that may cause future losses. Shore

up, ﬁre, retrain or recruit staff to reinforce the system.

3. Compile a list of weaknesses within the organisation and detail reasons for investment loss.

This exercise is a training tool for auditing and back-ofﬁce staff. Such forensic investigations

must feed active front-ofﬁce trading personnel, compelling them to document signiﬁcant

risk events for the beneﬁt of the back ofﬁce.

There is more incentive to promote this type of procedure under Basel II regulations for

market transparency and discipline. Part of the Basel II philosophy of risk is predicated on the

notion that top management want to grasp the nettle and actively manage OpRisk. The ﬁrst

thing forensic accounting can provide is a corporate health check or a company risk audit.

They may use a variety of techniques to derive this audit:

Self-assessment of risk areas – running a checklist audit or workshop to identify the strengths

and weaknesses of the company’s business environment, especially against potential stake-

holder lawsuits.

Risk mapping – diagramming the various constituent business units and process ﬂows.

Each area and its associated risk are identiﬁed and documented, then the follow-up risk

management action recommended. Risk mapping can be used within functional areas for key

risk indicators (KRIs). Departments can deﬁne operational limit bands of functionality like

a risk thermometer. Crossing these limits (e.g. asset-liability gaps) shows the company’s risk

“Forensic risk management – a sharpened fraud focus reduces litigation risk”, D.O. Burgess and C. Pacini, Journal of Forensic

Accounting, Vol.1, 2000.

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170 Investment Risk Management

exposure here is “hot”. The responsible party or group designated with the risk origination

can also be ﬂagged, and the risk management group alerted.

Business scorecards – these build on Kaplan and Norton’s seminal work in measuring and

quantifying the performance of corporations.

These are qualitative performance levels, but

the resulting scorecard can identify areas of weakness that may be reinforced with additional

capital and training.

Loss database – this keeps a historical log of above-threshold value ﬁnancial losses. Statis-

tically signiﬁcant losses or high damages can be highlighted automatically for the attention

of senior management.

We have developed advanced tools and techniques for:

Corporate governance.

Benchmarking and measuring performance.

Identifying areas of risk or weakness.

The problem is that an investor is an irrational animal and other inﬂuences often take over

the driver’s seat. This is certainly true at the top executive level, and OpRisk groups have less

to say about how strategic decisions are made.

The two main risk horizons remain for ﬁnancial institutions.

Strategic policy risk – the fundamental asset allocation and performance benchmark design.

This has been the subject of much research, but behavioural factors do exert a strong inﬂuence.

Strategic policy risk has the greatest inﬂuence upon bank and fund success. Governance and

trustee deﬁned roles working under a multilayered control hierarchy can keep a better link

between declared corporate objectives and the actions of managers.

Tactical implementation risk – investment manager structure and manager selection. Invest-

ment managers are generally recruited from a narrow band of skills and social backgrounds,

so they can develop a tendency to socialise and to invest as a herd. This leads to a restricted

range of assets chosen for investment. Careful interviewing and screening of recruits can

reduce undesired wayward behaviour.

APPROPRIATE RISK MANAGEMENT STRUCTURE

Effective counter-measures have to be put in place and tested. We have outlined some of the

Basel II guidelines for effective risk management. The trouble is: “Do you have the corporate

inﬂuence and the budget to get the proper risk management in place?”

Where advice and plans fall on deaf management ears, nothing concrete is likely to be done.

Budgetary constraint, as an opponent, is no stranger to the champion of risk management.

The ﬁnancial world is set on cutting costs and automating business processes; risk manage-

ment systems are just one facet of this drive. Yet, the quest for lower costs and automation can

blind us to the fundamental areas for error. Human intervention and room for exercise of staff

initiative can become stiﬂed.

OpRiskVision – Misys, Amelia systems, UK, January 2002.

“The balanced scorecard”, Kaplan R and Norton D, Harvard Business Review, 1996.

“Sound Practices for the Management and Supervision of Operational Risk”, Basel Committee for Banking Supervision, July

2002.

Structured Alpha: A Practical Application for Institution Funds, Watson Wyatt, December 1999.

Avoiding Disappointment in Investment Manager Selection, R. Urwin, paper to International Association of Consulting Actuaries,

March 1998.

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Future-Prooﬁng Against Risk 171

This is partly why human error is cited as the source of most operational failures. However, this is

often just an excuse for poor management and badly designed systems and processes that remove

checks and controls in an effort to improve efﬁciency by lowering costs.

Much of this corporate culture against disclosing the truth stems from the top of the ﬁnancial

institutions. Switzerland, for example, makes whistle-blowing a crime. Therefore, unfavourable

ﬁnancial assessments can remain hidden from the investors. Whistle-blowing really saves

investors money in the long run. It pinpoints the perpetrators of economic crimes and reduces the

period during which they could be removing or destroying economic capital of the company and

its shareholders. Whistle-blowing reduces the time-lag after which auditors and investigators

can look for relevant evidence.

CASE STUDY: BCCI BANK

Regulators worked apart, rather than together, on this case. It led to calls establishing supra-

national regulators; yet no world-wide “super regulator” exists anywhere. This disjointed

investigation enabled BCCI to continue its fraudulent operations. Yet, central bankers and

regulators preferred sealed lips for so long until all authorities could muster up enough

evidence and courage to act.

When BCCI closed in 1991, about one million depositors around the world lost their

money. The larger depositors included central banks and governments in major countries

around the world. BCCI had a cult of anonymity and banking secrecy for its customers.

BCCI systematically money-laundered around the world, supporting some unsavoury

regimes. It bribed and peddled inﬂuence systematically to foster extensive relationships

with prominent business, political and military ﬁgures in most of the 73 countries where it

operated.

The case demonstrates:

1. The value of business inﬂuence in protecting a ﬁnancial institution for a long time.

2. The value of prestige in “short-circuiting” investor common-sense.

3. The slowness and fragmented process of central banking and regulation.

By the late stage when BCCI was stopped, a lot of innocent people had been defrauded.

Once again, it had the elements of TBTF, reputation risk and corruption at the very core of

the top executives.

Whistle-blowing works on a raising series of red ﬂags. When there is no visible recourse,

or for major crimes, resort to an escalation of whistle-blowing. Alert the press and media,

then report to regulators, police and other supervisory authorities. A proper whistle-blowing

methodology can be set within the staff contract to lift the lid on fraud and crime. For minor

transgressions: keep the dissent internal initially and keep an account of all errors, crimes and

relevant data. Consult the ombudsman or newspaper if the company refuses to act.

Whistle-blowers must be protected and encouraged. Right now, the downside risk is be-

ing ﬁred or shunned in the professional for “squealing” on the company or colleagues, while

the upside potential is not much. Immediate risk is being questioned for technical compe-

tence, political competence, sanity, naivet´e; onus is on the whistle-blower to understand the

Measuring and Managing Operational Risk, p.13, C. Marshall, Wiley, 2001.

The Insolvency Liquidation of a Multinational Bank, Bank of International Settlements, December 1992.

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172 Investment Risk Management

President / CEO

Chief risk

officer

VP credit risk

mgmt.

VP trading risk

management

VP risk

solutions

VP risk

assessment

Risk assessment Risk solutions Insurable risk Internal audit

Figure 10.4 Risk organisation chart

Source: Global Association of Risk Professionals, GARP Risk Review, Mar–Apr 2002.

whole of the story; ﬁrst managerial reaction is often “you do not have a view on the whole

picture”.

Many corporations do not encourage whistle-blowing. Certainly, discouraging the leaks of

information is an overt attempt to block all events that present a corporate reputation risk.

Enron did not support whistle-blowing, but preferred to hide or shred the facts. Fraud and

concealment of the truth were deep-rooted in the structure of the company. Worse, the fraud

was perpetrated at the top. A company has to have a structure that is rooted in business and

risk management. See Figure 10.4.

Risk ignorance does not work, especially if the top management is ignorant or crooked.

What an open risk-managed structure does is to open the corporation to the control function

of the risk managers. They actively let the company be open to the idea that “squealers” can

inform on the company if something wrong or fraudulent is suspected.

An internal company “fraud hotline” should be set up, where anonymous whistle-blowing

can be channelled and processed for action. Nowadays, whistle-blowing is possibly anony-

mously through setting up temporary email accounts that access the regulatory website.

A US survey concluded that 6 % of business revenue or $400 billion is lost within the UK

economy as a result of fraud, and a most of this loss comes from internal staff. Furthermore,

KPMG estimated that only 4 % of these fraud incidents were spotted during external audit.

The reasons for this huge damage comes from a lack of internal corporate controls and poor

stock-control/accounting.

Many shareholder interest groups exist to protect the rights of the smaller investor. Grouped

together, they command a huge pension fund and inﬂuential voice. Calpers, Teachers, NAPF

and PIRC are among many. PIRC (Pensions and Investment Research Consultants) was vocal

in its criticism of arrogant boards that do not press forward to embrace corporate governance

recommendations.

PIRC has called for more transparent and accountable directorships to

e.g. www.fsa.gov.uk, www.SEC.gov, www.FBI.gov etc.

“Interviewing as a forensic-type procedure”, Journal of Forensic Accounting, vol.3, 2002.

“The effective non-executive director”, PIRC, www.PIRC.org.uk, 28 June 2002.

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Future-Prooﬁng Against Risk 173

make UK boards more geared towards increasing shareholder value and socially responsible

investment.

PIRC is an agency committed to SRI (socially responsible investment). It encourages in-

vestors to monitor how companies are managing their stakeholder relationships. One byproduct

is FTSE4Good as an index of SRI stocks that such investors can choose from. PIRC gives in-

vestors relevant information and SRI advice, particularly on corporate governance, including:

shareholder rights

best practice compliance

suitable board structures

remuneration schemes

investor relations.

PIRC has called for a series of changes to make UK board of directors more effective.

Encouraging more boards to have more non-executive directors than executives.

Making sure non-executives are genuinely independent rather than chums of the chief ex-

ecutive. PIRC says only 20 % of FTSE 100 boards have a majority of independent non-

executives.

Independent appraisal of board members.

A widening of the pool of non-executives. Companies could advertise for new recruits.

Better resources for non-execs, including secretaries and researchers as well as access to

independent research and advice.

More contact between non-execs and shareholders.

NAPF (National Association of Pension Funds) operates with a similar mission. Its pri-

ority is to ensure an efﬁciently regulated market for the provision of employer-sponsored

pensions. It advocates sound governance of pension fund assets as NAPF represents pension

funds that cover about 10 million UK employees. These funds control 20 % of the shares

of the London Stock Market. NAPF also opines that independent directors articulate the

wishes of their investors, while the non-executive directors fully understand the sharehold-

ers’ expectations of them. One role could be for them to exercise effective restraint over the

sympathetic remuneration committees that are inclined to pay the top executives too much

(“fat cats”).

Fat cats are blamed for skimming off the cream from the corporate milk, so impoverish-

ing their investors. Executives have to be charged with the duties of wealth creation and

safeguarding it through risk management, not for sleeping on the job. The risk management

directors’ duty is listed in the Basel II banking document that prescribes a healthy environ-

ment for business. It states that the function of risk management should go all the way to

the top:

The board of directors should be aware of the major aspects of the bank’s operational risks as a

risk category that should be managed, and it should approve and periodically review the bank’s

operational risk management framework. The framework should provide a ﬁrm-wide deﬁnition of

operational risk and lay down the principles of how operational risk is to be identiﬁed, assessed,

monitored and controlled/mitigated.

PIRC, www.Pirc.org.uk.

www.NAPF.org.uk.

Sound Practices for the Management and Supervision of Operational Risk, Bank of International Settlements, July 2002.

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174 Investment Risk Management

Invest within companies where there is a culture of openness and risk management. The new

Basel II banking regulations encourages corporate transparency. One’s conscience is better put

at rest than by a superﬁcial report that white-washes the remaining dangers.

We have looked at sensing for top management errors and lack of ethics deep down the

company – see AEW: advanced early warning.

Your sixth sense can save you a lot of money!

FACTS, NOT FIGURES

Corporate cover up works most of the times. When it does not, it boosts the impact. Covering

up transforms a high-probability low-impact risk into a low-probability high-impact risk.

Accounting analysis is generally the prior step before making the investment. Other proposals

are to invest where:

1. Accounting standards are strong enough to link reporting to reality.

2. Accounting statements from publicly quoted companies are accurate and timely, and a

regulatory framework exists to enforce the accounting principles.

There are other tell-tale signs to spot within the increasing onslaught of corporate PR and

white-wash:

Too optimistic sales forecasts – take your risk analytical Kalashknikov and shoot the balance

sheet apart.

Does the overall balance sheet “feel” right – too rapid a turnaround?

If the balance sheet is that good – then why are directors dumping their shares?

Do we have a good balance of voices on the board, or are they all in unison trying to get into

some scam?

Were there a few too many “balancing items”?

Which period were the majority of revenues booked and received (no receipt means no

revenue).

What sort of products and services were called revenue-producing?

Are they disposing of a lot of assets from the group?

Is the auditor also employed in another fee-paying activity within the company?

Another view for detecting cooked accounting books:

1) Record revenue too fast or too much.

2) Registering false revenue.

3) Increasing income with once-off gains.

4) Shifting expenses back or forwards into another period.

5) Reducing liabilities or completely omitting them.

6) Shifting current revenue forwards into a future period.

7) Shifting future expenses back or forwards into another period.

“Renewing conﬁdence in the markets”, D. Tweedie, Bank of England Financial Stability Review, December 2002.

“Cook the books and you will go directly to jail without passing go”, D.L. Crumbley and N. Apostolou, Journal of Forensic

Accounting, Vol.2, 2001.

Financial Shenanigans, Howard Schilit, McGraw-Hill Education, 2002.

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Future-Prooﬁng Against Risk 175

How long can this go on? It is not acceptable corporate behaviour, but if we are to believe

the regulators, it will continue as long as companies grow or change.

In each of the cases involving banks, management seemed to be content with the loss

of vigor in the process and the external auditor was apparently satisﬁed to simple collect a

fee. This is totally unacceptable. Further, as the organization evolves by offering new prod-

ucts, changing processes, outsourcing services, complying with the new regulations, or grow-

ing through mergers, the controls need to be modiﬁed to reﬂect the changes in risks. In

some case, the controls failed with respect to the newer risk exposures that were not iden-

tiﬁed, or growth put strains on existing control processes that were not suitable for a larger

organization.

Risk management means not sleeping on the job.

NEW RISK FOCUS

Risk management is a sequential series of tasks: analyse, forecast, investigate and mitigate

against risk. Risk reporting alone is just ﬁne for appearance – this is where many lax ﬁnancial

companies ran into trouble in recent years. Any reaction to a threat in such ﬁrms is likely to

be ineffective because the risk management function will be underfunded and understaffed.

Lack of training and proper risk management procedures result in a haphazard counter-attack

against risk. Organic risk management takes the human and team factors into account to build

a risk-managed corporation. This means an active risk outlook, not a passive one.

RAMP is a project methodology that has in-built self-checks to counter bias or project

deviation. It should be considered for managing ﬁnancial projects.

This way we can have a

real audit check that goes beyond simple numbers on the balance sheet, towards monitoring

the fundamental sources of business risk. RAMP provides a design template for implementing

a project. A brief extract of this process is shown in Figure 10.5:

Figure 10.5 Risk management project cycle

‘Strengthening compliance through effective corporate governance’, Susan Bies, Board of Governors, US Federal Reserve System.

11 June 2003.

Managing Project Risk, Y.Y. Chong, Financial Times Management, 2000.

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176 Investment Risk Management

1. Create liabilities and threats risk map.

2. Model long-term investment horizon plan.

3. Structure management control mechanism and project staff.

4. Set budget for risk management process.

5. Determine performance benchmarks.

6. Monitor active returns and performance; amend where needed.

7. Review results against plan and action.

The new focus is to provide concrete business beneﬁts through integrated risk management.

This progresses along a deﬁned risk management project cycle.

TLFeBOOK

Integrated Risk Management

We examine the risks that exist for the investor. We look initially at promising developments

in the ﬁnancial risk management, some of the leads that Basel II and RAMP offer. We then

complement this study with contributions from organic risk management (ORM). ORM offers

us some light into the continuing loss of control over miscreant CEOs, partly by separating

perceived reputation from reality. Ways of identifying deceit by forensic accounting and in-

terviewing are proposed. Unorthodox methods of hitting back at underperforming CEOs are

examined under the “Kalashnikov” school of risk management. We take a look at integrating

market, credit, operational and reputational risk views and how this can help meet business

challenges of the future.

DEVELOPMENTS IN THE FINANCE SECTOR

Risk is an everyday hazard that faces banks, funds and insurers. It can usually be mitigated,

but it is rarely eliminated completely. There are some cases where a positive “hazard” is a

very good thing to have – each business faces a risk or probability of making proﬁts. Millions

of people buy lottery tickets each day facing the small risk that they will become instant

multimillionaries. Business always encounters some form of risk.

It is good that we recognise that operational risks are present in our company. It is better when

we can predict the risk event that will happen. It is best when we have reinforced the general

resilience of our system through risk management countermeasures. The business operational

risk shock is going to be absorbed by our company, so the company has to respond.

Not all banks have put operational risk ﬁrmly on their corporate radar. Few banks seem

to have detailed an operational risk map by making provisions for expected operational risk.

Basel surveyed 89 banks, and only 33 had designated expected operational risk loss measures.

The actions varied – see Table 11.1.

Therefore, we need a management structure to plan the continuing and increasing system

resilience of the company.

Doing risk management, rather than merely talking about it, will separate the banks from

the boys for Basel II implementation. The measures of pricing, reserving and expensing for

OpRisk are already one signiﬁcant step ahead of risk managers simply answering:

We are risk-compliant because we have already submitted the Risk Compliance Report.

This reporting for the sake of reporting is a risk-ignorant form of control activity in a mindless

ticking of boxes in a questionnaire. Will reporting and complying with the regulations catch

out the next Enron?

The above techniques get us closer, may be, to a real-life model of risk management that

we call ‘organic’. Basel II reaches for some risk silo integration, but real life is messier. Messy

problems can be handled in a project management control structure, such as RAMP.

An investment company, with its people and processes, its clients and their investment needs

and preferences, is like a living organism. It can encompass every type of business risk, instead

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