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Not long ago, I was sitting on a trading floor,
helping a trader figure out the intricacies of volatility surfaces. The
firm's head of risk management strolled by, and the trader grunted an
expletive under his breath. I was taken aback by the trader's vehemence.
Not only did he dislike the head of risk management, it was visceral.
In many firms—most, perhaps—there is conflict between
trading (the "front office") and risk management (the "middle office").
At its most harmless, this takes the form of collegial banter and
humorous put-downs. At its worst, it is a blood sport, complete with
backstabbing, hoarding of information and political intrigue.
Sooner or later, every firm has a budding rogue
trader. Only one in a thousand is ever reported in the newspaper. The
vast majority are discovered before they can do much damage and are
quietly let go. In organizations where risk management works well, bad
apples are easy to spot. They are the one or two traders who are evasive
in their dealings with risk management. But those bad apples won't stand
out if there is a cold war raging between the front and middle offices.
In a context where every trader is evasive towards risk management, the
bad apples don't stand out. There are plenty of reasons to avoid
conflict, but this one alone is sufficient.
So how do we avoid conflict? Over the years, I have
come to identify two competing models for how financial risk management
should work. No organization implements either model in its pure form.
Rather, the two models are extremes. Organizations more or less blend
the two. However, as pure concepts, the two models can help us
understand what works and what doesn't work in financial risk
management. I have given the two models names. These are technical
terms, so I wouldn't want you reading too much into them, but one model
is called the Wrong Model and the other is called the Right Model.
To understand the two models, it is useful to
distinguish between strategic risk takers and tactical risk takers.
These labels take on different meanings in different contexts. For now,
strategic risk takers will be board members and senior management of a
corporation. They make strategic decisions that place the corporation's
assets at risk. Tactical risk takers will be traders, credit officers,
salespeople and middle managers. They make tactical decisions that place
the corporations assets at risk.
Presumably, we want there to be some link between
the decisions of one group and the decisions of the other. This requires
two-way communication. Strategic risk takers communicate down in the
organization with a business plan and formal policies and procedures.
These explain to tactical risk takers what tactical risks they should be
taking. They also detail the manners in which those risks should be
taken. Tactical risk takers communicate up in the organization with
reports (which may be prepared by others with their input). The reports
allow senior risk takers to monitor tactical risk taking to ensure it is
consistent with the vision they presented in the business plan. It also
allows them to assess what is working and what is not—so they can make
changes to the business plan, as necessary. Tactical risk takers also
communicate up in the organization with requests for changes to
procedures. Because these are usually prompted by developments—either
within the organization or in the organization's business
environment—such requests are a formal vehicle for strategic risk takers
to become aware of such developments.
There is nothing particularly new about any of
this. It is how corporations have operated for decades, if not
centuries. So where does financial risk management fit into the picture?
The two competing models offer very different answers.
According to the Wrong Model, strategic and
tactical risk takers aren't very good at assessing risk. They need help,
and that is where risk managers come in. Under this model, risk managers
are like super risk takers. They advise strategic risk takers on whether
to enter a market of expand into a new territory. They recommend whether
currency exposures should be hedged or not. They monitor the activities
of tactical risk takers—and intervene when risk gets out of hand.
There are many problems with the Wrong Model. First
of all, it addresses a problem that shouldn't even exist. It is the role
of strategic and tactical risk takers to take risk. They should be
experts at it. If they are not, the solution is not to hire some super
risk taker to help them. It is to fire them and replace them with people
who are more competent.
A second problem is the fact that the Wrong Model
holds no one accountable. If a CEO decides to take a particular risk
based on the advice of a risk manager, who is accountable when the risk
turns bad? Will it be the CEO's fault or the risk manager's?
Accountability is about one person taking responsibility. If two people
are accountable for the same decision, no one is really accountable.
Wherever the Wrong Model predominates, this problem
of ambiguous accountability causes conflict between the front and middle
offices. Traders' compensation and careers depend on their trading
performance. Having to share accountability with some risk manager
threatens their reputation and livelihood. For example, if a trader has
a successful quarter, does she deserve the credit? Or do we credit the
risk manager whose oversight presumably kept her from taking
inappropriate risks?
Traders are not the sorts of people to let grass
grow under their feet. When they feel threatened by risk managers, they
respond. They deny the risk managers information or feed them
misinformation. They undermine the risk managers within the organization
and generally promote a perception of the risk managers as "Keystone
Cops" who are incapable of contributing anything meaningful to their
trading decisions. Where the Wrong Model predominates, there is conflict
between the front and middle offices. It is pretty much inevitable.
The Right Model is profoundly different. It assumes
that an organization hires experts at taking strategic risk to serve as
strategic risk takers. It assumes that an organization hires experts at
taking tactical risk to serve as tactical risk takers. Risk managers
don't assist, advise or oversee any of these experts in doing their
jobs. Rather, risk managers facilitate the risk taking process. Risk
managers facilitate the drafting by strategic risk takers of business
plans, policies and procedures, and they ensure that these are
communicated to tactical risk takers. They facilitate the preparation of
risk reports and see that these are communicated to strategic risk
takers. They monitor to ensure that policies and procedures are
followed. To aid in that process, they facilitate requests for changes
to procedures whenever tactical risk takers identify a need. In a
nutshell, effective risk taking requires a constant flow of information
up and down the organization, and it is the role of financial risk
management to facilitate this information flow.
Under the Right Model, a better name for "risk
managers" would be "risk facilitators." Risk facilitators do not take
risk. They do not advise on risk. They have no opinions about risks. All
they do is ensure that strategic and tactical risk takers have all the
information they need to do their jobs. A risk facilitator may tell a
senior risk taker that a portfolio's value-at-risk is USD 750,000, but
it is up to the strategic risk taker to decide if that is acceptable or
not. As soon as a risk facilitator expresses an opinion on whether a
given risk is acceptable or not, that individual is contributing to the
risk taking process—and contributing to a blurring of accountability. A
key strength of the Right Model is that it promotes accountability by
putting one person's name on each risk.
Under the Right Model, conflict between the front
and middle offices is rare. When it does arise, it is usually a warning
signal that traders are engaged in activities they don't want strategic
risk takers knowing about. Otherwise, risk facilitators provide a
valuable service to traders, ensuring that they receive clear strategic
vision from the top and that their efforts are fairly and accurately
communicated to management. So long as traders now that risk
facilitators cannot and will not encroach on their own decision making,
there is every reason for traders and risk facilitators to work together
collegially toward the common goals detailed in the strategic risk
takers' business plans.
It is impossible to facilitate a process and
simultaneously be a participant in that process. This is why the Wrong
Model fails. The Right Model maintains a clear separation between risk
taking and risk facilitation roles. Risk takers take risk. Risk
facilitators do not. For risk facilitators, this is not a glamorous
role, but it is a profoundly important role.
Unfortunately, the Wrong Model predominates in many
organizations. It is sort of the default model people gravitate towards
without giving the matter much thought. The Right Model is more subtle.
It has to be explained to people, and they often aren't ready to embrace
it until they have experienced the failings of the Wrong Model first
hand.
Look around your own organization. Does the Wrong
Model predominate? If it does, the first step towards a solution is to
educate people. Explain the two competing models to them. Change
people's titles, so "risk managers" become "risk facilitators." Enforce
clear separation between risk taking and risk facilitation roles.
If you are a risk manager yourself, there is
something else you can do. The next time someone asks you whether a
particular risk is worth taking, answer them with "I don't have an
opinion on that."
Glyn A. Holton
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