Monday 16 November 2015

Risk Management Lessons From the Co-op Bank's Demise

One of the fallouts from the financial crisis in the UK was the demise of the Co-op Bank as part of the Co-operative movement.  The UK regulators (the PRA and the FCA) investigated the causes of the bank’s demise and issued simultaneous enforcement notices earlier this year (here and here).  The key failures identified by the regulators are summarised in Box 1. 
One of the key points for the press was the regulators decision to waive any financial penalties, reflecting the financial conditions of the Coop Bank.  However, from a risk management perspective, the enforcement notice represents an interesting catalogue of lessons in risk management for both banks and insurers: 

1.  Risks and business strategy go hand in hand.  It is difficult to manage risks effectively in the absence of a clear and comprehensive strategy for key lines of business. 

2.  A ‘cautious’ risk appetite statement is not enough.  Business decisions still must be evidenced as ‘cautious’ in practice even if this happens on a qualitative basis. 

3. The remit of the risk function includes valuations and accounting decisions.  This is particularly relevant in terms of the challenge and governance to (changes to) assumptions associated with discretionary features about valuation e.g. about the timing of redemption of capital instruments.   

4.  Policies are more than documents.   Compliance with policies must be evidenced.  A complex and changing business reality cannot be captured through prescriptive policies.  Certain discretions must be factored into decision making processes.  The risk oversight should cover how those discretions are applied in practice.   

5.   An open and cooperative relationship with the regulators is not just about issues.  It includes updating the supervisor regarding concerns about the position of senior individuals leading to intended changes.

6.  An effective risk culture is an outcome of business decisions about risk.  This was one of the concerns of the regulators.  The regulator’s articulation of an effective risk culture is interesting: ‘A culture in which accepted orthodoxies are challenged, action is taken to address risks on a timely basis and risk and control functions carry real weight is likely to support prudent management.’  In a nutshell, a risk culture is not end in itself but the means to support prudent management.

The enforcement notice mentions other issues regarding the shortcomings of the risk management oversight and internal audit. 

Finally, it is worth noting that the period of time formally considered by the regulators stretches from July 2009 – weeks before the Co-op Bank’s merger with the Britannia Building Society – to December 2013 – when it ceases to be a wholly owned subsidiary of the Co-op Group.   I don’t think the shortcomings just materialised in July 2009. 

This suggests that the perceived connection between responses to the financial crisis and strengthening risk management may not have been as widespread as it might have seemed.  The shortcomings are clearly serious and while they may not be critical when taken individually or addressed within a short period of time, it is the cumulative impact that had the effect of bringing the Co-op bank's demise.    

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This post is part of a series of posts on the practical lessons for risk management from enforcement cases.  The posts are all brought together in the page Enforcement Cases of Crescendo ERM blog.

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