全球風(fēng)險(xiǎn)管理專業(yè)人士協(xié)會(GARP)致力于為風(fēng)險(xiǎn)管理?xiàng)l線上的各級人員，包括各大金融機(jī)構(gòu)的風(fēng)險(xiǎn)從業(yè)者和監(jiān)管機(jī)構(gòu)人員提供風(fēng)險(xiǎn)教育和最新行業(yè)資訊。金程網(wǎng)校將持續(xù)轉(zhuǎn)載“GARP Risk Intelligence”系列文章，介紹科技、企業(yè)文化與治理、能源等領(lǐng)域?qū)Σ僮黠L(fēng)險(xiǎn)、信用風(fēng)險(xiǎn)、市場風(fēng)險(xiǎn)和資產(chǎn)負(fù)債管理的影響。讓我們一起全面認(rèn)識風(fēng)險(xiǎn)，防范風(fēng)險(xiǎn)，化解風(fēng)險(xiǎn)。

　　作為對過去幾年中一系列廣受矚目的風(fēng)險(xiǎn)管理危機(jī)的回應(yīng)，富國銀行(Wells Fargo)最近發(fā)布了一份《業(yè)務(wù)標(biāo)準(zhǔn)報(bào)告》，總結(jié)了其內(nèi)部調(diào)查結(jié)果和建議，對導(dǎo)致風(fēng)險(xiǎn)管理危機(jī)的業(yè)務(wù)和實(shí)踐作出補(bǔ)救。

　　該報(bào)告是每個銀行董事會和管理層必讀材料。以此，他們可以據(jù)此評估自己的做法，最終提出這樣一個關(guān)鍵問題： 現(xiàn)有的文化、治理、激勵薪酬和風(fēng)險(xiǎn)管理流程是否存在任何可能使我們陷入危險(xiǎn)的缺陷?本文總結(jié)了從富國銀行《業(yè)務(wù)標(biāo)準(zhǔn)報(bào)告》中我們能夠?qū)W到的五條教訓(xùn)。

　　教訓(xùn)1：銀行一旦失信，很難重獲信譽(yù)

　　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.”

　　教訓(xùn)2：避免業(yè)務(wù)、風(fēng)險(xiǎn)和審計(jì)職能之間的文化沖突

　　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.

　　教訓(xùn)3：面臨復(fù)雜風(fēng)險(xiǎn)的銀行董事會中有再多的風(fēng)險(xiǎn)專家也不為過

　　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.

　　教訓(xùn)4：業(yè)務(wù)成果直接反映了激勵薪酬制度的好壞

　　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.

　　教訓(xùn)5：風(fēng)險(xiǎn)管理流程是真正的安全網(wǎng)，而不僅僅是紙上談兵

　　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.

　　一些其他思考

　　Wells Fargo's problems could happen to any bank – small or large. Their report should be on the required reading list of all boards and management teams as a cautionary tale.

　　Understanding the ingredients of their risk demise – e.g., poor culture, insufficient governance, risk-amplifying incentive compensation plans and deficient risk processes – could keep your bank from becoming the next Wells Fargo.

　　Clifford Rossi博士是馬里蘭大學(xué)Robert H. Smith商學(xué)院的實(shí)務(wù)教授和駐校執(zhí)行官，也是切薩皮克風(fēng)險(xiǎn)顧問公司(Chesapeake Risk Advisors, LLC)的負(fù)責(zé)人。 他擁有近25年的金融風(fēng)險(xiǎn)管理經(jīng)驗(yàn)，曾在幾個主要銀行機(jī)構(gòu)擔(dān)任過多個C級高管職位。 在擔(dān)任現(xiàn)職之前，他是花旗集團(tuán)北美消費(fèi)者貸款部門的首席風(fēng)險(xiǎn)官。

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