My Son the Risk Manager?

That’s not a question for me.  I guess I am already there.  It is more of a potential question for my children – and yours as well.  The ultimate question is whether you would be happy to encourage your children (or perhaps the children of one of your best friends) to go into risk management as a career.

Put it differently, has risk management become like accountancy or law? Is risk-management a generic business qualification that can be applied in different business contexts?

Once I started thinking about this I realised that it wasn’t clear to me if risk management is a career in its own right.  The alternative is that risk management would be a common and reasonably well-defined role in many sectors.  This matters because one of the next questions in that hypothetical conversation would be along the lines of “how do I get there”.

The main argument in favour regarding risk management as a career in its own right is that there seems to be an emerging body of risk management theory that cuts across sectors.  This can be evidenced from the emergence of standardised approaches to risks management that cut across sectors, e.g. ISO 31000, and professional associations.

A similar argument would be in terms of the skills needed to perform successfully in the role.  While my experience is limited to financial services, my feeling is that the blend of skills needed in risk roles tend to be slightly different from those required for other roles – in no particular order, they include the ability to see the big-picture, communication, determination, ability to keep things simple.

At the same time, while developing tools and approaches for risk management is a considerable ongoing challenge, the main one is the implementation.  However, implementing successfully risk management and certainly generating value depends on business knowledge and understanding of the corporate environment.

All in all, I am more inclined to suggest to my children the following:

•  choose a degree you like – IT, law, economics, engineering, finance – and a sector; 
•  consider risk management as a role that would help career advancement; and
• explore ways of getting ready for that challenge.

If you work in financial services, I would be keen to hear your thoughts about these suggestions.  If you don’t, I would be keen to know if these lessons resonate with your experience. 

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Enforcement Lessons: 5 Lessons from a Fine Chance*

The UK Financial Conduct Authority (FCA) published recently the details (here) of an enforcement case involving Credit Suisse International (CSI) and Yorkshire Building Society (YBS).  They were fined for failing to meet the requirement that financial promotions are ‘clear, fair and not misleading’ £2m and £1.4m respectively.

Not much new so far but the circumstances of the case indicate how financial services are evolving and the challenges for risks management.

The case involves a structured product providing capital protection, a guaranteed minimum return and the potential for achieving a higher return under certain conditions related to the performance of FTSE100 index.  CSI manufactured the product and YBS distributed (most of) it.  The product raised nearly £800m and reached 84 thousand customers.

At the heart of this case there is a concern that product complexity can reach a level such that it is difficult to ensure that disclosures to retail customers are clear, fair and not misleading.  For example, the FCA was concerned that the disclosures suggested that this was a simple index tracker – it wasn’t.  This can distort customers’ ability to infer the likelihood of a maximum return. 

In addition, there are five interesting points to take away from this case:

1.    Distribution arrangements give rise to significant conduct risk, even if no financial advice is provided.    

2.    The chances of relevant events need to be taken into account in financial promotions.  A ‘maximum return’ that can be achieved with nearly zero probability based on past history is not really a ‘maximum return’!

3.    Third party consumer advocates can have an impact.  The UK Consumers Association (‘Which?’) approached YBS and CSI in September 2010 with concerns about financial promotions and the chance of achieving the maximum return advertised.  This resulted in limited changes to disclosures: more emphasis on the conditions required to achieve the maximum return and less emphasis on the presentation of the maximum return.

4.    The target consumer group has practical importance.  The disclosures will be crucial to ensure appropriate consumer outcomes if you are targeting ‘stepping stone customers’, ‘typically conservative, risk averse customers’, with a structured product and don’t offer advice.

5.    Slow reaction to regulatory developments persists.   The relevant period when the breach took place stretches to 30 months from November 2009 to June 2012.  The earlier intervention by ‘Which?’ and concerns raised by the FCA had limited effect. 

It is interesting to see all these different factors coming together in a case.  This may be one of the few occasions (if not the first) where a fine results because financial promotions did not take into account the chances of the underlying events. 

If you work in financial services, I would be keen to hear your thoughts about these lessons for the management of conduct risk.  If you don’t, I would be keen to know if these lessons resonate with your experience. 

* Thanks to my colleagues for suggesting a title.

If you found this interesting, you can subscribe to future posts at http://crescendo-erm.blogspot.co.uk and receive them by email - no more than once a week.  You will need to provide an email address and then confirm the subscription.  Your email address will not be shared.  Alternatively, if we share a group in “LinkedIn” you can choose "follow" Isaac Alfon.