GARP：我们能从富国银行报告中学到什么教训？
行业资讯 | 2019-02-26
作为对过去几年中一系列广受瞩目的风险管理危机的回应，富国银行（Wells Fargo）最近发布了一份《业务标准报告》，总结了其内部调查结果和建议，对导致风险管理危机的业务和实践作出补救。
该报告是每个银行董事会和管理层必读材料。以此，他们可以据此评估自己的做法，最终提出这样一个关键问题： 现有的文化、治理、激励薪酬和风险管理流程是否存在任何可能使我们陷入危险的缺陷？本文总结了从富国银行《业务标准报告》中我们能够学到的五条教训。》》更多金融证书相关问题点我咨询
教训1：银行一旦失信，很难重获信誉
Wells Fargo's fall from grace is a genuine case study of enterprise risk management gone awry. While problems for Wells Fargo may have first surfaced in 2016 – with revelations that millions of retail customer accounts had been opened without their authorization – practices in several other business areas （including mortgage and auto lending） suggest that the control breakdowns in the retail bank were not an isolated event.
Lesson number one from this experience is that the long-term effect of reputation risk far outweighs any short-term business objectives. Wells Fargo currently faces an immense credibility problem, since anything it says can only be measured against its actions, which in this case speak volumes about an environment that undermined the company's stated risk philosophy of only taking “prudent risks.”
教训2：避免业务、风险和审计职能之间的文化冲突
The root of any risk management event lies in poor risk culture. The phrase “poor risk culture” itself has become overused, only because there have been so many bank risk incidents over the years where culture has played a role in excessive risk-taking.
Two issues identified in the Wells Fargo report should be troubling to any bank. One is special deference that control functions, such as corporate risk management and internal audit, may exhibit under certain circumstances toward business functions. Finding the right balance between being a watchdog or a lap dog for the second and third lines of defense is an essential ingredient in ensuring the three-lines-of-defense model works effectively.
Likewise, business areas that limit the flow of risk information to control functions – or otherwise stymie their oversight – erode the necessary enterprise checks and balances that keep a bank from veering off course.
One way of telling how progressive boards and management are in cultivating a strong risk culture is how the bank views and leverages the CRO. A balanced focus on risk and return can only come with parity in the stature of the CFO and CRO positions.
Don't wait until a risk event happens at your firm to change the culture. By then, the damage has been done and moral high ground has been lost.
教训3：面临复杂风险的银行董事会中有再多的风险专家也不为过
One of the most important responsibilities of a board is to provide effective challenge to management. Those two words have enormous implications for who serves on a board. To be effective and to ask the proper questions, a board risk committee member must possess a requisite understanding of risks.
Bank risks – particularly those of a firm as complex as Wells Fargo – cannot be overseen by boards lacking experience in bank risk management. While having diverse professional backgrounds can be useful for some board committees, the ideal candidates for board risk committees at large banks should have direct risk management expertise working at such institutions. Only one of the seven current Wells Fargo board risk committee members appear to have that expertise.
The other essential attribute of an effective board member is the ability to challenge management. Over time this can become difficult, as boards can become complacent as they gain familiarity and comfort with management.
Fundamentally, the buck stops with the board when serious problems arise. Under those circumstances, board shakeups are the bank's way of upgrading their board talent to ensure credible challenge.
Wells Fargo touts several personnel changes to their board as part of their response efforts, but they still have more work ahead. Nearly half of its current risk committee were on the board during the years preceding the retail account incident.
教训4：业务成果直接反映了激励薪酬制度的好坏
Poorly designed incentive compensation plans destroy efforts to enhance culture and strengthen governance and risk controls. In the end, such plans become the catalyst for forging a wedge between the first, second and third lines of defense.
Consistent with what recent Nobel laureates in economics have found, bank management behavior is greatly affected by financial incentives. Compensation plans heavy on business objectives will invariably drive behavior in the first line that tends to be more short-term and riskier.
Moreover, stretch goals are fine, so long as they are balanced with long-term risk-based targets. Along with board risk committees, CROs need to be heavily involved in overseeing the firm's incentive compensation plans.
教训5：风险管理流程是真正的安全网，而不仅仅是纸上谈兵
The Wells Fargo report highlights several of the bank's risk management practices that are consistent with the OCC's Heightened Expectations standards for large banks. For instance, the report goes into some detail describing how the three lines of defense doctrine works at Wells Fargo.
The problem is that the final rules for Heightened Expectations were released by the OCC in 2014, before the scandals that rocked the bank. Given the breakdowns that the report cites between all three lines of defense, there seems to have been some deficiencies – at both Wells Fargo and the OCC – in implementing critical risk processes.
Sometimes the essence of an effective standard or policy can be lost without strong management support and implementation. It is not easy to turn a policy or control document into a process that is not just implemented but also executed and embraced across the enterprise. This all circles back to strong risk culture.
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