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Answer Upon - Basel II's Three Approaches to Operational Risk Management
Funny Interview Questions evance of historical loss data, including those situations in which judgment overrides or other adjustments may be used, to what extent they may be used and who is authorized to make such decisions. Internally generated operational risk measures used for regulatory capital purposes must be based on a minimum five-year observation period of internal loss data. However, when the bank first moves to the AMA, a three-year historical data window is acceptable.Job Interview is generally a set of questions asked by the interviewer to test the ability of a candidate, his/her knowledge and personality. It is the employer’s way of assessing prospective candidates, to find if they are good enough for the job for which the company is recruiting. During the interview process the interview will ask different types of questions to know more about the candidate. In most of the companies the interview questions is divided into different types.Job interview questions differ according to the work structure of a company. But most of the job interview questions asked by the companies are related to the three categories. In the first set, the interview asks about the candidate’s family background, education, and interests. The second set comes with question meant to assess the technical knowledge of the candidate. While the last is to judge the candidate’s personality – his/her nature, decision making capacity, ideology, and ability to solve problems.But some interview boards also ask a few funny interview questions to the candidate. This is a tricky method to check the candidate’s reaction. Many candidates don’t know how to answer a funny interview question. Hearing a funny interview question some candidates get irritated. What is there in getting irritated hearing a funny interview question? The candidates have to know that these questions are meant to check the psychological structur To qualify for regulatory capital purposes, a bank's internal loss collection processes must be able to map its historical internal loss data into the relevant supervisory categories as are defined in detail in the Basel II Annexes. The bank must have documented objective criteria for allocating losses to the specified business lines and event types. A bank's internal loss data must be comprehensive. It must capture all material activities and exposures from all appropriate sub-systems and geographic locations. The bank must be able to justify that any excluded activities or exposures, both individually and in combination would not significantly impact the overall risk estimates. This should be based on an appropriate minimum gross loss threshold for internal loss data collection. Additionally, a bank should collect information relating the date of the event, any recoveries of loss amounts, as well as descriptive information about the drivers or causes of the loss event. The level of detail in any descriptive information should be appropriate to the size of the gross loss amount. Operational risk losses that are related to credit risk and have traditionally been included in banks’ credit risk databases (e.g. collateral management failures) must continue to be treated as credit risk for the purposes of calculating minimum regulatory capital. It follows that such losses will not be subject to the operational risk capital charge. Nevertheless, for the purposes of internal operational risk management, banks must identify all material operational risk losses consistent with the scope of the definition of operational risk and the defined event types, including those related to credit risk. A bank’s operational risk measurement system must use pertinent e How Do You Advance Your Career? The operational risk requirements of Basel II proposes three measurement methodologies for calculating the operational risk capital charges. These are the Basic Indicator Approach, the Standardized Approach and the Advanced Measurement Approach.Position yourself for promotions, better customers and pay raises. Follow and adjust an annual plan with dates. Take time every day to see if you are on track. Program yourself to do this everyday as part of your Career Management Regimen…the repetition will get you where you want to be. (change your behavior if you don't have time to plan - investing in planning time will save time! Also, don't hold yourself back while planning - you can't steer a ship that is not moving!)Set your personal benchmarks – goals. Compare with the expectations your customers/boss/company have for you. Be on the same page with documented rewards: “When I accomplish (A,B and C), I will realize (these additional responsibilities) for compensation that looks like (this)”.• Make sure you have a clear job description• Write down how you are going to improve the job description for your replacement. What are you doing to challenge the roleCommunicate reaching/beating them. This is not a one discussion plea at your review or in December. What if you beat your goals and still don’t realize your pre-determined rewards? Is management dragging it out, why: Maybe it is a tough year and nobody is getting a raise. Are there other environmental risks that you missed? What have you learned in a scenario like this?Building a Strategic Career Plan (SCP) should accomplish the internal (your strengths and weaknesses) an Under the Basic Indicator Approach banks must hold capital for operational risk equal to the average over the previous three years of a fixed percentage (15% for this approach) of positive annual gross income (figures in respect of any year in which annual gross income was negative or zero are excluded). Although no specific criteria are set out for use of the Basic Indicator Approach, banks using this method are encouraged to comply with the Committee’s guidance on “Sound Practices for the Management and Supervision of Operational Risk” (BIS; February 2003). These principles require: •A hands on approach in the creation of an appropriate risk management environment, •Positive actions in the identification, assessment, monitoring and control of operational risk, •Adequate public disclosure. Under the Standardized Approach a bank’s activities are divided into eight business lines. Within each business line, gross income is a broad indicator that serves as a stand-in for the level of business operations and therefore the probable size of operational risk exposure within each of these business lines. The capital charge for each business line is calculated by multiplying gross income by a factor (called the “beta”) assigned to that business line. The beta serves as a substitute for the industry-wide relationship between the operational risk loss experience for a given business line and the aggregate level of gross income for that business line. The business lines and the beta factors range from 12% for “retail banking”, “asset management” and “retail brokerage”; 15% for “commercial banking” and “agency services” to 18% for “corporate finance”, “trading & sales” and “payment & settlement”. The total capital charge is calculated as the three-year average of the simple summation of the regulatory capital charges across each of the business lines in each year. In any given year, a negative capital charges (as a result of negative gross income) in any business line may offset positive capital charges in other business lines without limit. At national supervisory level, the supervisor can choose to allow a bank to use the Alternative Standardized Approach (ASA) provided the bank is able to satisfy its supervisor that this alternative approach provides an improved basis for measurement of risks. Under the ASA, the operational risk capital charge/methodology is the same as for the Standardized Approach except that two business lines – “retail banking” and “commercial banking” where a fixed factor ‘m’ – replaces gross income as the exposure indicator and is related to the extent of loans granted in these areas. Under the Advanced Measurement Approaches (AMA) the regulatory capital requirement equals the risk measure generated by the bank’s internal operational risk measurement system using specific quantitative and qualitative criteria. Use of the AMA is subject to supervisory approval. Supervisory approval has to be conditional on the bank being able to show to the satisfaction of the supervisory authority that the allocation mechanism for these subsidiaries is appropriate and can be supported empirically. The quantitative standards that apply to internally generated operational risk measures for purposes of calculating the regulatory minimum capital charge are that any internal operational risk measurement system must be consistent with the definition of operational risk and a range of defined loss event types (covering all operational aspects such as fraud, employee practices, workplace safety, business practices, processing practices, business disruption and loss of physical assets). To qualify for use of the Advanced Measurement Approaches (AMA), a bank must satisfy its supervisor that, •The banks board of directors and senior management, are actively involved in the oversight of the operational risk management framework; •The bank has an operational risk management system that is conceptually sound and which includes an independent operational risk management function that is responsible for the design and implementation of the bank’s operational risk management framework; •The bank has It has sufficient resources to use this approach in the major business lines as well as the control and audit areas. A bank using the AMA will be subject to a period of initial monitoring by its supervisor before it can be used for regulatory purposes. This period will allow the supervisor to determine if the approach is credible and appropriate. The bank’s internal measurement system must be able to reasonably estimate unexpected losses based on the combined use of internal and relevant external loss data, scenario analysis and bank-specific business environment and internal control factors. The bank’s measurement system must also be capable of supporting an allocation of economic capital for operational risk across business lines in a manner that creates incentives to improve business line operational risk management. Additionally, •The operational risk management function is responsible for documenting policies and procedures concerning operational risk management and controls, designing and implementing the bank’s operational risk measurement methodology, designing and implementing a risk-reporting system for operational risk, and developing strategies to identify, measure, monitor and control/mitigate operational risk, •The bank’s internal operational risk measurement system must be closely integrated into the day-to-day risk management processes of the bank and its output must be an integral part of the process of monitoring and controlling the bank’s operational risk profile. This information must play a major role in risk reporting, management reporting, internal capital allocation, and risk analysis. •Operational risk exposures and loss experience must be reported regularly to business unit management, senior management, and to the board of directors. •The bank’s operational risk management system must be well documented and the bank must have a routine in place for ensuring compliance with a documented set of internal policies, controls and procedures concerning the operational risk management system, which must include policies for the treatment of noncompliance issues. •Internal and/or external auditors must perform regular reviews of the operational risk management processes and measurement systems. This review must include both the activities of the business units and of the independent operational risk management function. •The validation of the operational risk measurement system by external auditors and/or supervisory authorities must include the verification that the internal validation processes are operating in a satisfactory manner; and making sure that data flows and processes associated with the risk measurement system are transparent and accessible. In particular, it is necessary that auditors and supervisory authorities are in a position to have easy access, whenever they judge it necessary and under appropriate procedures, to the system’s specifications and parameters. Because the analytical approaches for operational risk continue to evolve the approach or distributional assumptions used to generate the operational risk measure for regulatory capital purposes is not being specified by the Basel Committee. A bank must however be able to show that its approach captures potentially severe ‘tail’ loss events. Irrespective of the approach is used, a bank must demonstrate that its operational risk measure meets a soundness standard comparable to that of the internal ratings-based approach for credit risk. Based on this, bank supervisors will require the bank to calculate its regulatory capital requirement as the sum of expected loss (EL) and unexpected loss (UL), unless the bank can demonstrate that it is adequately capturing EL in its internal business practices (to base the minimum regulatory capital requirement on UL alone, the bank must be able to demonstrate to the satisfaction of its national supervisor that it has measured and accounted for its EL exposure). A bank needs to have a credible, transparent, well-documented and verifiable approach for weighting these basic elements in its overall operational risk measurement system. Internal loss data is critical to linking a bank's risk estimates to its actual loss experience. Such data is most relevant when it is clearly linked to a bank's current business activities, technological processes and risk management procedures. To do this a bank must have documented procedures for assessing the on-going relevance of historical loss data, including those situations in which judgment overrides or other adjustments may be used, to what extent they may be used and who is authorized to make such decisions. Internally generated operational risk measures used for regulatory capital purposes must be based on a minimum five-year observation period of internal loss data. However, when the bank first moves to the AMA, a three-year historical data window is acceptable. To qualify for regulatory capital purposes, a bank's internal loss collection processes must be able to map its historical internal loss data into the relevant supervisory categories as are defined in detail in the Basel II Annexes. The bank must have documented objective criteria for allocating losses to the specified business lines and event types. A bank's internal loss data must be comprehensive. It must capture all material activities and exposures from all appropriate sub-systems and geographic locations. The bank must be able to justify that any excluded activities or exposures, both individually and in combination would not significantly impact the overall risk estimates. This should be based on an appropriate minimum gross loss threshold for internal loss data collection. Additionally, a bank should collect information relating the date of the event, any recoveries of loss amounts, as well as descriptive information about the drivers or causes of the loss event. The level of detail in any descriptive information should be appropriate to the size of the gross loss amount. Operational risk losses that are related to credit risk and have traditionally been included in banks’ credit risk databases (e.g. collateral management failures) must continue to be treated as credit risk for the purposes of calculating minimum regulatory capital. It follows that such losses will not be subject to the operational risk capital charge. Nevertheless, for the purposes of internal operational risk management, banks must identify all material operational risk losses consistent with the scope of the definition of operational risk and the defined event types, including those related to credit risk. A bank’s operational risk measurement system must use pertinent ex Success Secrets of a Billionaire ) in any business line may offset positive capital charges in other business lines without limit.I have to admit I was surprised by his answer.Let me explain.Yesterday I was reading one of my favorite magazines, Business 2.0, and there was a story I wanted to read on page 88.But I didn't go right there, I started at page 1 and, by the time I got to page 88, I was ready for some great success tips.And I got them.2 things specifically stood out in my mind to share with you.They had an interview with Jim Clark.Jim Clark became a billionaire in the 'internet age.'He was involved in starting Netscape, Silicon Graphics, and dozens of start up companies.This guy knows a ton about the MINDSET you need to succeed and increase your in.come.I want to share with you 1 question and 1 answer from the interview because it can help you.Question: "What Traits Should Every Good Entrepreneur Possess?"Answer: Discontent and anxiety. Most entrepreneurs are not content with the way things are. But if they're smart, they're extremely anxious too. Most ideas are going to happen whether you do them or someone else does.It's the person who feels most anxious about it and builds the prototype who is likely to win.The best entrepreneurs tend to move quickly and efficiently. They don't waste a lot of time making decisions.I want to touch on an important point Jim is making because I rarely hear anyone else say it but myself.A lot of people At national supervisory level, the supervisor can choose to allow a bank to use the Alternative Standardized Approach (ASA) provided the bank is able to satisfy its supervisor that this alternative approach provides an improved basis for measurement of risks. Under the ASA, the operational risk capital charge/methodology is the same as for the Standardized Approach except that two business lines – “retail banking” and “commercial banking” where a fixed factor ‘m’ – replaces gross income as the exposure indicator and is related to the extent of loans granted in these areas. Under the Advanced Measurement Approaches (AMA) the regulatory capital requirement equals the risk measure generated by the bank’s internal operational risk measurement system using specific quantitative and qualitative criteria. Use of the AMA is subject to supervisory approval. Supervisory approval has to be conditional on the bank being able to show to the satisfaction of the supervisory authority that the allocation mechanism for these subsidiaries is appropriate and can be supported empirically. The quantitative standards that apply to internally generated operational risk measures for purposes of calculating the regulatory minimum capital charge are that any internal operational risk measurement system must be consistent with the definition of operational risk and a range of defined loss event types (covering all operational aspects such as fraud, employee practices, workplace safety, business practices, processing practices, business disruption and loss of physical assets). To qualify for use of the Advanced Measurement Approaches (AMA), a bank must satisfy its supervisor that, •The banks board of directors and senior management, are actively involved in the oversight of the operational risk management framework; •The bank has an operational risk management system that is conceptually sound and which includes an independent operational risk management function that is responsible for the design and implementation of the bank’s operational risk management framework; •The bank has It has sufficient resources to use this approach in the major business lines as well as the control and audit areas. A bank using the AMA will be subject to a period of initial monitoring by its supervisor before it can be used for regulatory purposes. This period will allow the supervisor to determine if the approach is credible and appropriate. The bank’s internal measurement system must be able to reasonably estimate unexpected losses based on the combined use of internal and relevant external loss data, scenario analysis and bank-specific business environment and internal control factors. The bank’s measurement system must also be capable of supporting an allocation of economic capital for operational risk across business lines in a manner that creates incentives to improve business line operational risk management. Additionally, •The operational risk management function is responsible for documenting policies and procedures concerning operational risk management and controls, designing and implementing the bank’s operational risk measurement methodology, designing and implementing a risk-reporting system for operational risk, and developing strategies to identify, measure, monitor and control/mitigate operational risk, •The bank’s internal operational risk measurement system must be closely integrated into the day-to-day risk management processes of the bank and its output must be an integral part of the process of monitoring and controlling the bank’s operational risk profile. This information must play a major role in risk reporting, management reporting, internal capital allocation, and risk analysis. •Operational risk exposures and loss experience must be reported regularly to business unit management, senior management, and to the board of directors. •The bank’s operational risk management system must be well documented and the bank must have a routine in place for ensuring compliance with a documented set of internal policies, controls and procedures concerning the operational risk management system, which must include policies for the treatment of noncompliance issues. •Internal and/or external auditors must perform regular reviews of the operational risk management processes and measurement systems. This review must include both the activities of the business units and of the independent operational risk management function. •The validation of the operational risk measurement system by external auditors and/or supervisory authorities must include the verification that the internal validation processes are operating in a satisfactory manner; and making sure that data flows and processes associated with the risk measurement system are transparent and accessible. In particular, it is necessary that auditors and supervisory authorities are in a position to have easy access, whenever they judge it necessary and under appropriate procedures, to the system’s specifications and parameters. Because the analytical approaches for operational risk continue to evolve the approach or distributional assumptions used to generate the operational risk measure for regulatory capital purposes is not being specified by the Basel Committee. A bank must however be able to show that its approach captures potentially severe ‘tail’ loss events. Irrespective of the approach is used, a bank must demonstrate that its operational risk measure meets a soundness standard comparable to that of the internal ratings-based approach for credit risk. Based on this, bank supervisors will require the bank to calculate its regulatory capital requirement as the sum of expected loss (EL) and unexpected loss (UL), unless the bank can demonstrate that it is adequately capturing EL in its internal business practices (to base the minimum regulatory capital requirement on UL alone, the bank must be able to demonstrate to the satisfaction of its national supervisor that it has measured and accounted for its EL exposure). A bank needs to have a credible, transparent, well-documented and verifiable approach for weighting these basic elements in its overall operational risk measurement system. Internal loss data is critical to linking a bank's risk estimates to its actual loss experience. Such data is most relevant when it is clearly linked to a bank's current business activities, technological processes and risk management procedures. To do this a bank must have documented procedures for assessing the on-going relevance of historical loss data, including those situations in which judgment overrides or other adjustments may be used, to what extent they may be used and who is authorized to make such decisions. Internally generated operational risk measures used for regulatory capital purposes must be based on a minimum five-year observation period of internal loss data. However, when the bank first moves to the AMA, a three-year historical data window is acceptable. To qualify for regulatory capital purposes, a bank's internal loss collection processes must be able to map its historical internal loss data into the relevant supervisory categories as are defined in detail in the Basel II Annexes. The bank must have documented objective criteria for allocating losses to the specified business lines and event types. A bank's internal loss data must be comprehensive. It must capture all material activities and exposures from all appropriate sub-systems and geographic locations. The bank must be able to justify that any excluded activities or exposures, both individually and in combination would not significantly impact the overall risk estimates. This should be based on an appropriate minimum gross loss threshold for internal loss data collection. Additionally, a bank should collect information relating the date of the event, any recoveries of loss amounts, as well as descriptive information about the drivers or causes of the loss event. The level of detail in any descriptive information should be appropriate to the size of the gross loss amount. Operational risk losses that are related to credit risk and have traditionally been included in banks’ credit risk databases (e.g. collateral management failures) must continue to be treated as credit risk for the purposes of calculating minimum regulatory capital. It follows that such losses will not be subject to the operational risk capital charge. Nevertheless, for the purposes of internal operational risk management, banks must identify all material operational risk losses consistent with the scope of the definition of operational risk and the defined event types, including those related to credit risk. A bank’s operational risk measurement system must use pertinent e Be Careful Who You Pick As A Partner In Your Business es to use this approach in the major business lines as well as the control and audit areas.If you are contemplating setting up a business and taking partners in to help you, you would do well to give this serious thought before making promises, shaking hands or signing contracts with anybody.Having been involved in a number of business startups, I have witnessed a phenomenon, which has proven itself again and again. People are great starters and lousy finishers and this is especially true for “business associates’ or “partners” who you may be counting on to help you start or operate your business.You should keep in mind that nobody cares about your business enterprise more than you and the first mistake you will make is believing that others are willing to work as hard as you, give as much time, effort and/or money. At the beginning of a new venture, when hopes are high and enthusiasm abounds, you may be surrounded by people who agree with the potential success of your project and agree to help you. It’s after the business is started, when things don’t go as planned, when costs are high and sales are low or non-existent, that the real character of your associates will be revealed. This is why careful thought combined with the help of an attorney can be beneficial by drafting very specific partnership agreements to protect you and your business.In general, you want a mutual understanding between you and your potential partner to be very specific regarding their role in the business, the service A bank using the AMA will be subject to a period of initial monitoring by its supervisor before it can be used for regulatory purposes. This period will allow the supervisor to determine if the approach is credible and appropriate. The bank’s internal measurement system must be able to reasonably estimate unexpected losses based on the combined use of internal and relevant external loss data, scenario analysis and bank-specific business environment and internal control factors. The bank’s measurement system must also be capable of supporting an allocation of economic capital for operational risk across business lines in a manner that creates incentives to improve business line operational risk management. Additionally, •The operational risk management function is responsible for documenting policies and procedures concerning operational risk management and controls, designing and implementing the bank’s operational risk measurement methodology, designing and implementing a risk-reporting system for operational risk, and developing strategies to identify, measure, monitor and control/mitigate operational risk, •The bank’s internal operational risk measurement system must be closely integrated into the day-to-day risk management processes of the bank and its output must be an integral part of the process of monitoring and controlling the bank’s operational risk profile. This information must play a major role in risk reporting, management reporting, internal capital allocation, and risk analysis. •Operational risk exposures and loss experience must be reported regularly to business unit management, senior management, and to the board of directors. •The bank’s operational risk management system must be well documented and the bank must have a routine in place for ensuring compliance with a documented set of internal policies, controls and procedures concerning the operational risk management system, which must include policies for the treatment of noncompliance issues. •Internal and/or external auditors must perform regular reviews of the operational risk management processes and measurement systems. This review must include both the activities of the business units and of the independent operational risk management function. •The validation of the operational risk measurement system by external auditors and/or supervisory authorities must include the verification that the internal validation processes are operating in a satisfactory manner; and making sure that data flows and processes associated with the risk measurement system are transparent and accessible. In particular, it is necessary that auditors and supervisory authorities are in a position to have easy access, whenever they judge it necessary and under appropriate procedures, to the system’s specifications and parameters. Because the analytical approaches for operational risk continue to evolve the approach or distributional assumptions used to generate the operational risk measure for regulatory capital purposes is not being specified by the Basel Committee. A bank must however be able to show that its approach captures potentially severe ‘tail’ loss events. Irrespective of the approach is used, a bank must demonstrate that its operational risk measure meets a soundness standard comparable to that of the internal ratings-based approach for credit risk. Based on this, bank supervisors will require the bank to calculate its regulatory capital requirement as the sum of expected loss (EL) and unexpected loss (UL), unless the bank can demonstrate that it is adequately capturing EL in its internal business practices (to base the minimum regulatory capital requirement on UL alone, the bank must be able to demonstrate to the satisfaction of its national supervisor that it has measured and accounted for its EL exposure). A bank needs to have a credible, transparent, well-documented and verifiable approach for weighting these basic elements in its overall operational risk measurement system. Internal loss data is critical to linking a bank's risk estimates to its actual loss experience. Such data is most relevant when it is clearly linked to a bank's current business activities, technological processes and risk management procedures. To do this a bank must have documented procedures for assessing the on-going relevance of historical loss data, including those situations in which judgment overrides or other adjustments may be used, to what extent they may be used and who is authorized to make such decisions. Internally generated operational risk measures used for regulatory capital purposes must be based on a minimum five-year observation period of internal loss data. However, when the bank first moves to the AMA, a three-year historical data window is acceptable. To qualify for regulatory capital purposes, a bank's internal loss collection processes must be able to map its historical internal loss data into the relevant supervisory categories as are defined in detail in the Basel II Annexes. The bank must have documented objective criteria for allocating losses to the specified business lines and event types. A bank's internal loss data must be comprehensive. It must capture all material activities and exposures from all appropriate sub-systems and geographic locations. The bank must be able to justify that any excluded activities or exposures, both individually and in combination would not significantly impact the overall risk estimates. This should be based on an appropriate minimum gross loss threshold for internal loss data collection. Additionally, a bank should collect information relating the date of the event, any recoveries of loss amounts, as well as descriptive information about the drivers or causes of the loss event. The level of detail in any descriptive information should be appropriate to the size of the gross loss amount. Operational risk losses that are related to credit risk and have traditionally been included in banks’ credit risk databases (e.g. collateral management failures) must continue to be treated as credit risk for the purposes of calculating minimum regulatory capital. It follows that such losses will not be subject to the operational risk capital charge. Nevertheless, for the purposes of internal operational risk management, banks must identify all material operational risk losses consistent with the scope of the definition of operational risk and the defined event types, including those related to credit risk. A bank’s operational risk measurement system must use pertinent e How to Write Ad Copy That Sells asurement systems. This review must include both the activities of the business units and of the independent operational risk management function.In our fast-paced society we all want quick results, delivery now, quick customer service, overnight shipping, etc. Why is that? The reason is simple -- "Time Is Money!"Picture this, a website with class "A" graphics, a beautiful flash menu, video with sound and all the bells & whistles. Now imagine this beautiful website without any physical words at all. How many sales do you think it would make?Rudyard Kipling once said, "Words are, of course, the most powerful drug used by mankind." Words make us laugh, cry and fall in love. Words have started wars and ended them. Same thing holds true when writing ad copy for your web site. The words you use have the power to positively explode your sales, or completely terminate them.Great copywriters of the advertising age have given us tested formulas for the mechanics of writing effective sales copy. Attention-getting headlines, body copy which appeals to your readers' emotions, and benefit-laden bullet points. You must answer the question "what's in it for me?" While you're at it, don't forget to build credibility, ask for the sale, offer a bonus and finish with a P.S. that reiterates the call to action.You write the ad copy but something is still missing. What you may have left out is the importance of style and delivery. Great copywriters, like great musicians, have practiced their delivery for years, honing their skills to razor sharpness. Like a Les •The validation of the operational risk measurement system by external auditors and/or supervisory authorities must include the verification that the internal validation processes are operating in a satisfactory manner; and making sure that data flows and processes associated with the risk measurement system are transparent and accessible. In particular, it is necessary that auditors and supervisory authorities are in a position to have easy access, whenever they judge it necessary and under appropriate procedures, to the system’s specifications and parameters. Because the analytical approaches for operational risk continue to evolve the approach or distributional assumptions used to generate the operational risk measure for regulatory capital purposes is not being specified by the Basel Committee. A bank must however be able to show that its approach captures potentially severe ‘tail’ loss events. Irrespective of the approach is used, a bank must demonstrate that its operational risk measure meets a soundness standard comparable to that of the internal ratings-based approach for credit risk. Based on this, bank supervisors will require the bank to calculate its regulatory capital requirement as the sum of expected loss (EL) and unexpected loss (UL), unless the bank can demonstrate that it is adequately capturing EL in its internal business practices (to base the minimum regulatory capital requirement on UL alone, the bank must be able to demonstrate to the satisfaction of its national supervisor that it has measured and accounted for its EL exposure). A bank needs to have a credible, transparent, well-documented and verifiable approach for weighting these basic elements in its overall operational risk measurement system. Internal loss data is critical to linking a bank's risk estimates to its actual loss experience. Such data is most relevant when it is clearly linked to a bank's current business activities, technological processes and risk management procedures. To do this a bank must have documented procedures for assessing the on-going relevance of historical loss data, including those situations in which judgment overrides or other adjustments may be used, to what extent they may be used and who is authorized to make such decisions. Internally generated operational risk measures used for regulatory capital purposes must be based on a minimum five-year observation period of internal loss data. However, when the bank first moves to the AMA, a three-year historical data window is acceptable. To qualify for regulatory capital purposes, a bank's internal loss collection processes must be able to map its historical internal loss data into the relevant supervisory categories as are defined in detail in the Basel II Annexes. The bank must have documented objective criteria for allocating losses to the specified business lines and event types. A bank's internal loss data must be comprehensive. It must capture all material activities and exposures from all appropriate sub-systems and geographic locations. The bank must be able to justify that any excluded activities or exposures, both individually and in combination would not significantly impact the overall risk estimates. This should be based on an appropriate minimum gross loss threshold for internal loss data collection. Additionally, a bank should collect information relating the date of the event, any recoveries of loss amounts, as well as descriptive information about the drivers or causes of the loss event. The level of detail in any descriptive information should be appropriate to the size of the gross loss amount. Operational risk losses that are related to credit risk and have traditionally been included in banks’ credit risk databases (e.g. collateral management failures) must continue to be treated as credit risk for the purposes of calculating minimum regulatory capital. It follows that such losses will not be subject to the operational risk capital charge. Nevertheless, for the purposes of internal operational risk management, banks must identify all material operational risk losses consistent with the scope of the definition of operational risk and the defined event types, including those related to credit risk. A bank’s operational risk measurement system must use pertinent e How Over Regulations Hurts the Little Guy evance of historical loss data, including those situations in which judgment overrides or other adjustments may be used, to what extent they may be used and who is authorized to make such decisions. Internally generated operational risk measures used for regulatory capital purposes must be based on a minimum five-year observation period of internal loss data. However, when the bank first moves to the AMA, a three-year historical data window is acceptable.We have all heard horrendous stories of how over regulation crushes small business people who compete with the big dogs in various markets. It seems as if the government regulators are merely there to crush the little guy sometimes so that the big boys with lobbyist budgets can get the government to intervene via some Congressmen, Councilman, Senator, Corrupt Judge or County Supervisor.Well here is a story that is truly outrageous indeed; a total abuse of the system, but the Sierra Club. You see, I met someone recently who owned a mine in just North of Albuquerque in the hills about Santa Fe, New Mexico. Get this, he had a ten-mile road and the Sierra Club was made because he owned a mine.He never mined anything just loved the landscape and was able to use his retirement money and got the property for a song. He was planning on building his dream home there in fact. So the Sierra Club filed a lawsuit stating that the rules and regulations said that he had to water the dirt road. He lived outside of Midland, TX a state away, but told me of this story in Starbucks Coffee shop in Santa Fe.Turns out the cost to water the road once a day for a year was astronomical due to water shortages in New Mexico, costs and remoteness for the water truck, 5 loads to water the road. So he paved it, but the Sierra Club pressed the lawsuit so now he waters a paved road in the middle of the biggest drought in the history of New To qualify for regulatory capital purposes, a bank's internal loss collection processes must be able to map its historical internal loss data into the relevant supervisory categories as are defined in detail in the Basel II Annexes. The bank must have documented objective criteria for allocating losses to the specified business lines and event types. A bank's internal loss data must be comprehensive. It must capture all material activities and exposures from all appropriate sub-systems and geographic locations. The bank must be able to justify that any excluded activities or exposures, both individually and in combination would not significantly impact the overall risk estimates. This should be based on an appropriate minimum gross loss threshold for internal loss data collection. Additionally, a bank should collect information relating the date of the event, any recoveries of loss amounts, as well as descriptive information about the drivers or causes of the loss event. The level of detail in any descriptive information should be appropriate to the size of the gross loss amount. Operational risk losses that are related to credit risk and have traditionally been included in banks’ credit risk databases (e.g. collateral management failures) must continue to be treated as credit risk for the purposes of calculating minimum regulatory capital. It follows that such losses will not be subject to the operational risk capital charge. Nevertheless, for the purposes of internal operational risk management, banks must identify all material operational risk losses consistent with the scope of the definition of operational risk and the defined event types, including those related to credit risk. A bank’s operational risk measurement system must use pertinent external data (either public data and/or pooled industry data), especially when there is any possibility to believe that the bank is potentially exposed to severe losses, however infrequent. Additionally a bank must use scenario analysis of expert opinion in conjunction with external data to evaluate its exposure to high-severity events.
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