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If I were still a regulator, here's what I'd ask ๐—Ÿ๐—น๐—ผ๐˜†๐—ฑ๐˜€ ๐—•๐—ฎ๐—ป๐—ธ about their risk function '๐˜ณ๐˜ฆ๐˜ด๐˜ต๐˜ณ๐˜ถ๐˜ค๐˜ต๐˜ถ๐˜ณ๐˜ช๐˜ฏ๐˜จ'.




Earlier this week, the Financial Times reported that:


Lloyds Banking Group ๐˜ข๐˜น๐˜ฆ๐˜ด ๐˜ณ๐˜ช๐˜ด๐˜ฌ ๐˜ด๐˜ต๐˜ข๐˜ง๐˜ง ๐˜ข๐˜ง๐˜ต๐˜ฆ๐˜ณ ๐˜ฆ๐˜น๐˜ฆ๐˜ค๐˜ถ๐˜ต๐˜ช๐˜ท๐˜ฆ๐˜ด ๐˜ค๐˜ฐ๐˜ฎ๐˜ฑ๐˜ญ๐˜ข๐˜ช๐˜ฏ ๐˜ต๐˜ฉ๐˜ฆ๐˜บ ๐˜ข๐˜ณ๐˜ฆ ๐˜ข โ€˜๐˜ฃ๐˜ญ๐˜ฐ๐˜ค๐˜ฌ๐˜ฆ๐˜ณโ€™.


๐˜“๐˜ฆ๐˜ฏ๐˜ฅ๐˜ฆ๐˜ณ โ€˜๐˜ฉ๐˜ข๐˜ท๐˜ช๐˜ฏ๐˜จ ๐˜ต๐˜ฐ ๐˜ด๐˜ข๐˜บ ๐˜จ๐˜ฐ๐˜ฐ๐˜ฅ๐˜ฃ๐˜บ๐˜ฆโ€™ ๐˜ต๐˜ฐ ๐˜ฆ๐˜ฎ๐˜ฑ๐˜ญ๐˜ฐ๐˜บ๐˜ฆ๐˜ฆ๐˜ด ๐˜ข๐˜ด ๐˜ฑ๐˜ข๐˜ณ๐˜ต ๐˜ฐ๐˜ง ๐˜ฆ๐˜ง๐˜ง๐˜ฐ๐˜ณ๐˜ต ๐˜ต๐˜ฐ โ€˜๐˜ฎ๐˜ฐ๐˜ท๐˜ฆ ๐˜ข๐˜ต ๐˜จ๐˜ณ๐˜ฆ๐˜ข๐˜ต๐˜ฆ๐˜ณ ๐˜ฑ๐˜ข๐˜ค๐˜ฆโ€™


This seems counterintuitive.


A bank that has previously been in trouble for poor risk management shouldn't see the risk function as a blocker, reduce its resourcing or otherwise clip its wings.


Now, it is entirely possible that the changes being proposed are designed to โ€” and willย โ€” enhance risk management. But I have my doubts.


Unfortunately, I'm not in a position to ask the firm to explain themselves.


But my former colleagues at the regulators are.



๐—œ๐—ป ๐—ง๐—ต๐—ฒ ๐—ฆ๐—ฝ๐—ผ๐˜๐—น๐—ถ๐—ด๐—ต๐˜


As a regulator, you can't โ€” nor should you โ€” second-guess or intervene in every decision firms make.


But given the way this has been presented, the regulators ๐˜ค๐˜ข๐˜ฏ and ๐˜ด๐˜ฉ๐˜ฐ๐˜ถ๐˜ญ๐˜ฅ ask probing questions, such as:


1. Staff within the risk function have been described as a '๐˜ฃ๐˜ญ๐˜ฐ๐˜ค๐˜ฌ๐˜ฆ๐˜ณ'. Please provide specific examples of what they have blocked that has led to this description, why you believe they should not have done so and what types of transactions or activities you are expecting them to approve in the future that they would not have done in the past. โ€จ

ย ย 

2. What impact do you think that description will have on the people remaining within the function, how they are perceived by the organisation and, therefore, your overall risk culture? โ€จ


3. What concerns do you think we will have about this, and how have you personally satisfied yourself that you can monitor and address the risks this poses from a regulatory perspective?


Where I went next would depend on the answers I got. Particularly to question two.


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Image: courtesy of ChatGPT from an early draft of this blog. Not sure about the flower, but the 'Mastermind' style quiz setting seems apt.

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