Since the global financial crisis, we see clear improvement in risk management and oversight at banks. Capital levels have been boosted and leverage has come down. However, there are still many banks that do not incorporate any risk management metric into remuneration and incentive plans. Investors should therefore continue the dialogue with banks on this topic.
In its 2009 report on the lessons learned from the financial crisis, the OECD stated: “Perhaps one of the greatest shocks from the financial crisis has been the widespread failure of risk management. […] Boards were in a number of cases ignorant of the risk facing the company. […]”
Without proper risk management there cannot be proper banking. It is imperative that investors feel comfortable with a bank’s risk management track record and framework. Senior executives need to communicate to the capital market how risk categories impact capital allocation. The Board is the ultimate body that has to monitor risk management and investors need to have enough reassurance about the level of Board expertise and the strength of risk management committees.
To assess the development of risk management we have analyzed the RobecoSAM dataset for global developed markets banks on their risk management scores. We have done this for 28 European banks, 23 North American banks and 17 Asia-Pacific banks over 2011-2016. We draw the following conclusions:
We have also looked at the risk-weighting of bank assets. Our analysis shows that European banks started deleveraging in 2008-2009, whereas it took Asia-Pacific banks another three years. North American banks actually increased their risk-weighted assets from 2012 onwards.
Robust risk management ideally goes hand in hand with strong corporate governance. The three-lines-of-defense model is widely known, capturing three levels:
Sufficient risk management expertise has to be available on the Executive Committee and the Chief Risk Officer (CRO) needs to be sufficiently senior. We have analyzed a collection of 12 international banks. Our research shows that most banks have appointed a new generation of CROs since the global financial crisis. Half of the CROs in our sample have prior internal experience in risk management. In only two out of our twelve banks the CRO has experience in risk management outside the current organization. We would like to see this number increase.
The average experience in risk management is about nine years, which just includes the global financial crisis experience. In most cases shorter risk management tenure tends to coincide with no or limited prior risk management experience in the own organization. This is a potential red flag. Ideally, we would like to see a range of diversity in terms of experience, market and perspective. In terms of gender diversity, there is only one female CRO in our sample.
Many Boards recognize the importance of risk management and have set up committees to focus on this. Elements we find important are that bank boards use dedicated and standalone risk committees, or a hybrid form. The risk committees should be independent and comprise enough risk management and general financial expertise in and outside the current organization.
We find that a stand-alone risk committee is the dominant model. The committee is fully independent in seven out of twelve banks. The least desirable situation is where a former CEO is Chairman of the Board and also Chair of the risk committee. In two cases the former CEO is member of the risk committee. We would strongly advise against this.
Only 15% of the cases, the members of the risk committee have relevant expertise. In five out of twelve cases no one on the risk committee had relevant expertise.
Another important issue is the degree to which risk management metrics are part of the bank executives’ scorecard. With the exception of HSBC, none of the banks in our sample have some sort of risk management metric as part of their Long-Term Incentive Plan (LTIP). The balance between S(hort)TIP and LTIP should receive more attention as it can be seen as a good proxy for risk management. For example, large STI awards relative to LTI encourage gaming and short-term risk taking.
Have we built better banks? Yes, in the sense that banks have built better risk management and oversight structures. Capital levels have been boosted and leverage in the system has declined. No, in the sense that many banks still do not incorporate any risk management metric into their incentive plan. Investors should continue the dialogue with banks, asking the right questions about risk management and risk oversight. Let’s build better banks together!
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商号等： ロベコ・ジャパン株式会社 金融商品取引業者 関東財務局長（金商）第２７８０号
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