| While the focus has traditionally
been on the investment risk borne by a portfolio, recent events in
the investment management community have shown that market risk is
not the only risk that pension plans are exposed to.
Operational risk is commonly defined as the
risk of direct or indirect loss resulting from inadequate or failed
internal processes, people and systems or from external events.
Considering the vagueness of operational risk and given the many
factors that can affect it, a number of questions quickly come to
mind. How does a plan sponsor ascertain the operational strengths
or weaknesses of each of their external managers? How can these
risks be quantified? And how can operational risk be measured in
such a way that the information is meaningful?
It is recognized that operational risk factors
are qualitative and quantitative in nature and require a unique
management approach. So how do you start measuring operational risk?
The plan sponsor could send an audit team into each firm, but this
approach is not very practical. There is no real industry standard
or best practice in place, and this approach would be quite expensive.
And what would you do with the results? How do you know if controls
are strong or weak? And how can you compare these operational strengths
and weaknesses across a diverse set of investment managers?
One proposal is to use a self-assessment
approach in the form of a questionnaire that outlines the best practice
capabilities within each area of the investment manager's organization.
The purpose would be to compare current controls and procedures
to common industry goals. Now most, if not all, of the questions
would be qualitative in nature. But if you factor in a scoring rationale,
or a quantitative component that weights the responses, you can
start to get an idea of strengths and weaknesses in each area of
the investment manager's operations. Once all your managers and
potential managers have completed a self-assessment survey, plan
sponsors can use the results as a basis for discussion with the
fund manager, aimed at rewarding strong operational controls and
discouraging non-compliance with industry standards.
The key challenge in adopting a self-assessment
approach is having a consistent and industry-accepted framework.
To achieve this, collaboration between plan sponsors and fund managers
is essential. Implemen-tation of an industry-standard measurement
will result in a win-win situation. Plan sponsors get to assess
operational risk in a way that is measurable, comparable and meaningful.
The implementation of an industry-standard measurement mitigates
the potential of large losses due to operational inefficiencies
or violations. And, compared to other alternatives, it offers a
cost-efficient method of measuring operational risk.
On the other side, investment managers benefit
by showcasing their strong operational controls, learning about
industry best practices, proactively improving internal policies,
and being well prepared for regulatory visits.
The need for plan sponsors to manage operational
risk in their fund is no different than the need to measure investment
risk, or any other risk for that matter. Operational risk may seem
intangible in nature and often difficult to quantify, but the losses
are real, and could potentially have a large impact on the future
of the fund. *
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