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© The Z/Yen Group of Companies 2008
| |
Professor Michael Mainelli, Executive Chairman, Z/Yen Group Limited
[An edited version of this article first
appeared as "Chapter 10: Correlation Causes Questions: Environmental Consistency
Confidence In Wholesale Financial Institutions", Dennis Cox (ed), Frontiers
of Risk Management: Key Issues and Solutions, pages 94-100, Euromoney Books
(2007)]
Introduction
Wholesale financial institutions have tried a number of approaches for managing
and modelling operational risk, with limited success. Z/Yen Limited have
developed an approach called Environmental Consistency Confidence meaning,
basically, if you can predict incidents and losses with some degree of
confidence, then your modelling is useful. It is often said that
“correlation doesn’t demonstrate causation”. That is true, but “correlation
should cause questions”. The core of Environmental Consistency Confidence is
using modern statistical models to manage financial institutions through the
examination of correlations between activity and outcomes. This paper sets
out how Environmental Consistency Confidence works, how it differs slightly from
other approaches, its basis in system dynamics, its fundamental concept of
Predictive Key Risk Indicators for Losses and Incidents (PKRIóLI),
and two early trials showing promising results.
Wholesale financial institutions have tried applying system dynamics and
modelling techniques from at least the 1970’s with minimal returns.
Investment banks have modelled trading floors in order to see how to optimise
trade flows, large payments processors have tried modelling their multi-path
networks in order to optimise processing time and security. Further, Basel
II initiatives led numerous wholesale institutions to document their operations
in order to show their control of operational risk. Nevertheless, a few
decades on, it is clear that the application of formal system dynamics modelling
tools is rare, at least in the minds of systems modelling experts, when compared
with some other industries.
Wholesale financial institutions may have smaller transaction volumes than
retail institutions, but even a modest investment bank can process 250,000
equity trades a week. The very largest investment banks might handle 40
million equity trades a year and large amounts of foreign exchange, money
markets and other instruments. With large numbers of transactions,
numerous paths and variable activity levels this should be a fruitful
environment for the application of system dynamics, yet most wholesale
operations managers do not believe that system dynamic techniques bear fruit.
A number of factors contribute to this lack of apparent benefit. Firstly,
wholesale trading finance is a fast-changing environment with little time for
analytical reflection and a need for quick pay-back on investment in operations.
Secondly, there has been only a modest amount of emphasis on the ‘back-office’
processing operations; most of the emphasis has been on supporting the
‘front-office’ trading floor. Thirdly, wholesale institutions tend to
respond positively to regulatory initiatives setting out operations standards,
but otherwise do what everyone else is doing. Thus, despite a few trials
of system dynamics approaches, since almost no one has a big success story in an
environment where rapid, perhaps overly rapid, decisions are taken, almost no
one will undertake a systems modelling project.
Operational Risk
According to §644 of the “International Convergence of Capital Measurement and
Capital Standards” (June 2004) from the Bank for International Settlements,
known as Basel II (see
http://www.bis.org/publ/bcbs107.htm), operational risk is defined as the
“risk of loss resulting from inadequate or failed internal processes, people and
systems, or from external events.” Since operational risk became a regulatory
discussion topic in the early 1990’s, a number of approaches have been tried to
both measure it and manage it, and been found wanting. Arguably, the
evolution of current thinking about operational risk has already had three
stages:
-
OpVAR – “operational value-at-risk”. This was
an early approach that attempted to treat operational risk in the same
manner as market and credit risk. The basic idea was to build a large,
stochastic model of the various operational risks and use Monte Carlo
simulations to calculate a “value-at-risk” that would allow a financial
institution to set aside an appropriate amount of capital. This
approach requires probability distributions of operational risk, in the same
way banks analyse market movements or credit defaults. A few industry
initiatives attempted to collect large datasets of operational risk losses,
e.g. defalcation by employees, but found that the data was heterogenous and
difficult to extract because of its sensitivity – who wants to admit
publicly they’ve been defrauded. OpVAR still has a place as a useful
analytical check, but not as a primary means of measuring and managing
operational risk;
-
Process modelling – many financial
institutions documented their operations in order to analyse their
operational risks. Many of the tools used to document the operations
were also the same tools used to input models to system dynamics simulation
software. While this also led many institutions to experiment with
system dynamics techniques, they then encountered problems of validating the
models and chaos theory effects, i.e. extreme sensitivity to initial
conditions. Further, this approach failed to provide a useful measure
for banks to calculate an appropriate amount of capital to set aside to
cover operational risk;
-
Risk dashboards or ‘radar’ – some financial
institutions explored the application of compliance tools that required
operational managers to prove that they had followed procedures that
minimised operational risk. While this heuristic approach is
culturally suited to banks (it’s bureaucratic ‘tick-bashing’ and
form-filling with which they are familiar), it also fails to provide an
overall measure of operational risk. Further, there was little
consideration of the human systems within which this approach was being
applied so, for instance, people just repeatedly answered questions with the
desired answer, e.g. “is your computer room secure” – “yes”, thus negating
any benefit. Finally, this approach results in a lot of RAG
(red-amber-green) type reports that cannot be readily summarised numerically
and are incapable of contrasting different risks other than by their
frequency or place in the taxonomy. So, with little account taken of
the severity, five open computer room door incidents may be rated more
important than a single total power outage.
Elements of these three approaches are still
used, and useful, but on their own they do not provide measurement and
management of operational risk. There are some other approaches worth
noting. Though these have not been as popular, they may have more
long-lasting benefits:
-
Culture change – as operational risk is
primarily risk generated by people internally (people fail to follow
processes or deliberately sabotage or make poor decisions), a culture that
promotes reduced operational risk should provide significant benefits [Howitt,
Mainelli and Taylor, 2004]. This approach, however, does not provide a
measure of operational risk for capital purposes;
-
Cost-per-transaction variance – this approach
attempts to contrast operational risk across products by fully allocating
costs to each transaction, thus generating a more typical distribution curve
for risk [Mainelli, May 2004]. This approach does find system dynamic
modelling useful, to help allocate pooled costs based on activity levels
(activity-based costing), and does appear to work in practice and across the
industry. However, this approach has not been widely adopted, possibly
because the full-blown version requires extensive, and expensive, systems
modelling, and possibly because the regulators have been slow to see that it
does help them provide comparable metrics, though those metrics are not
traditional.
Another approach worth evaluating, that leads to
a slightly different view of how system dynamics is applied to the organisation,
is the use of Key Risk Indicators.
What Is A Key Risk Indicator (KRI)?
|
“Key Risk Indicators: risk indicators
are statistics and/or metrics, often financial, which can provide
insight into a bank’s risk position. These indicators should
be reviewed on a periodic basis (often monthly or quarterly) to
alert banks to changes that may be indicative of risk concerns.
Such indicators may include for example the number of failed trades,
staff turnover rates and the frequency and/or severity of errors and
omissions.”
Basel Committee on Banking Supervision, “Sound Practices for the
Management and Supervision of Operational Risk”, December 2001.
“KRIs are measurable metrics or indicators that track different
aspects of operational risk.”
The Risk Management Association, The KRI Banking Study,
2005, page 5.
|
A working definition is “regular measurement
based on data which indicates the operational risk profile of a particular
activity or activities”. KRIs can be environmental, operational or
financial. For instance, environmental indicators (that might turn out
to be KRIs) could be such things as trading volumes and volatilities on
major commodities or foreign exchange markets. Operational indictors
(that might be KRIs) could be general activity levels in the business,
numbers of deals, mix of deals, number of amendments, staff turnover,
overtime or IT downtime. Financial indicators (that might be KRIs)
could be things such as deal volatility, dealing profit, activity-based
costing variances or value of amendments.
The key link is to apply a more scientific approach to managing risk.
Firms must test the usefulness of operational risk data collection by using
losses or incidents to discover what the indicators should have been.
In other words, what drives operational risk ? We describe this approach as
predictive key risk indicators to/from loss/incidents prediction (PKRIóLI).
The important point to note is that people can suggest many possible risk
indictors (RIs), but they are not Key Risk Indicators (KRIs) unless they are
shown to have predictive capability for estimating losses and incidents.
A KRI must contribute to the predictability of losses and incidents in order
to be validated as a KRI. If an RI does not predict losses or
incidents, it remains an interesting hypothesis, someone’s unvalidated
opinion. Experience does help to identify the true drivers of
operational risk and should help focus attention and control actions, but
the PKRIóLI
approach supports and validates (or invalidates) expert judgement of true
drivers of operational risk losses. The intention of this approach is
not to replace expert judgement, but to support that judgement in a more
systematic way in an ever-changing environment.
Why Are KRIs Important?
KRIs are important for at least four reasons:
-
KRIs measure probable operational risk arising over a
time period, as opposed to tracking operational risk, and thus make an
appropriate management tool for operational risk;
-
KRIs help to form an input for economic capital
calculations by helping to produce estimates of future operational risk
losses and thus helping to set a base level of capital for operational
risk;
-
KRIs are increasingly examined by rating agencies,
e.g. Moody’s or Standard & Poors, and financial analysts;
-
KRIs are increasingly important to regulators.

Without capturing incidents and loss data,
there is nothing to predict. Sound incident data capture is a
prerequisite for anything but the most basic capital allocation under Basel
II. It is worth quoting at length from Basel II (see
http://www.bis.org/publ/bcbs107.htm for full text) as this shows what
regulators expect both for operational risk and for key risk indicators
676. In addition to using loss
data, whether actual or scenario-based, a bank’s firm-wide risk
assessment methodology must capture key business environment and
internal control factors that can change its operational risk profile.
These factors will make a bank’s risk assessments more forward-looking,
more directly reflect the quality of the bank’s control and operating
environments, help align capital assessments with risk management
objectives, and recognise both improvements and deterioration in
operational risk profiles in a more immediate fashion. To qualify
for regulatory capital purposes, the use of these factors in a bank’s
risk measurement framework must meet the following standards:
-
The choice of each factor needs
to be justified as a meaningful driver of risk, based on experience
and involving the expert judgment of the affected business areas.
Whenever possible, the factors should be translatable into
quantitative measures that lend themselves to verification.
-
The sensitivity of a bank’s risk
estimates to changes in the factors and the relative weighting of
the various factors need to be well reasoned. In addition to
capturing changes in risk due to improvements in risk controls, the
framework must also capture potential increases in risk due to
greater complexity of activities or increased business volume.
-
The framework and each instance of
its application, including the supporting rationale for any
adjustments to empirical estimates, must be documented and subject
to independent review within the bank and by supervisors.
-
Over time, the process and the
outcomes need to be validated through comparison to actual internal
loss experience, relevant external data, and appropriate adjustments
made.
There are a number of KRI initiatives in the
financial services industry to share best practice on KRIs and loss/incident
reporting or collection. A leading initiative is the Risk Management
Association’s “KRI Banking Study”, KRIeX (see www.kriex.org), in which some
50 banks defined 1,809 KRIs, though the relevance of these has not been
tested using PKRIóLI
prediction (to be fair, there has been some talk of doing something at an
unspecified point in the future). Some examples of the Risk Management
Association’s KRIs are the percentage of transactions requiring manual
input, percentage of unsettled transactions after due dates and theft/1,000
ATMs. A breakdown of the KRIs by category and number is set out in the
diagram below:

It is implausible to ask any organisation to
track 1,809 key risk indicators. To be fair, only 74 indicators are
common and apply to virtually all risk points. Further, only (sic) 533
are “high-risk points”. While some participants may be involved in order to
“done to be seen” by regulators, KRIeX is a valuable resource. This is
an exhaustive approach at an early stage that does help by providing a
starting set of RIs, but the KRIs for different institutions must evolve
from individual institutional experience, rather than being imposed
over-heavily from a template. The table below sets out the
characteristics of a KRI as seen by the Risk Management Association:
|
Effectiveness |
Comparability |
Ease of Use |
|
Indicators should... |
Indicators should... |
Indicators should... |
|
1. Apply
to at least one
risk point, one specific
risk category, and one
business function.
2. Be
measurable at
specific points in time.
3.
Reflect objective
measurement rather than subjective judgment
4. Track
at least one aspect of the loss profile or event history, such as
frequency, average severity, cumulative loss, or near-miss rates.
5.
Provide useful management information. |
1. Be quantified as an amount, a percentage, or a
ratio. 2. Be reasonably precise and
define quantity.
3. Have values that are comparable over time.
4. Be comparable internally across businesses.
5. Be reported with primary values and be
meaningful without interpretation to some more subjective measure.
6. Be auditable.
7. Be identified as comparable across
organisations (if in fact they are.) |
1. Be available reliably on a timely basis.
2. Be cost effective to collect.
3. Be readily understood and communicated. |
In a sense the choice is between what is currently done
informally (no significant business lacks RIs) and what could be done better
through more formality, statistics and science to make them KRIs. For
each KRI, there needs to be definition and specification. The Risk
Management Association’s template specification structure gives a flavour of
what this means:
|
Definition |
Specification |
Guidance |
-
KRI
Number
-
KRI
Name
-
Description
-
Rationale/Comments
-
Nature
-
Type
-
Typography
-
Ratings
|
- Specification Version
- Term Definitions
- Value Kind
- Dimensions
- Limitations on Scope
- Buckets
- Bucket Variants
- Definition Thresholds
- Measurement Rules
- Underlying KRIs
- Calculation Method
- Benchmark Rules
- Aggregation Method
- Scaling Denominator
- Scaling Rules
|
- Usage
- Collection Frequency
- Reporting Frequency
- Frequency of Change
- Collection Level
- Variants
- Directional Information
- Extraneous Information
- Control Indicator
- Source
|
PKRIóLI
Issues
One could readily conclude that a
fairly static KRI can’t be “key”. For example, a KRI such as the number of
lawsuits received by a particular function might change very little for long
periods. In this case one might wish to examine “lawsuits in period”
or “estimated settlement values” or other more sensitive measures than just
a very slow-changing “outstanding lawsuits”. However, what matters is
whether or not the KRI contributes to the capability of predicting
operational losses/incidents, not its variability.
There is overlap between KRIs and Key Performance Indicators (KPIs). It
would be easy to say that KRIs are forward-looking and KPIs are
backward-looking, but far too simplistic. There are clearly overlaps.
For instance, high trading volumes and high volatility on one day might be
good performance indicators predicting a high-likelihood of good future
financial performance turnout for that day, but also indicative of emerging
operational risks from that day.
KRIs that increase in some ranges and decrease in others can cause confusion
as KRIs are not necessarily linear. For example, staff overtime might
be an example of a KRI with a bell-shaped curve. No overtime may
indicate some level of risk as people aren’t paying attention or do tasks
too infrequently; modest levels of overtime may indicate less risk as staff
are now doing a lot of familiar tasks; and high rates of overtime may
indicate increased risk again through stress. KRIs help to set ranges
of acceptable activity levels. There can be step changes in
operational risk associated with a KRI. For instance, a handful of
outstanding orders at the close of day may be normal, but risk might
increase markedly when there are over a dozen outstanding orders. KRIs
should vary as risk changes, but they don’t have to vary linearly.
What about all the stuff that’s taken for granted? For example, electricity
and water supplies may seem to be an important consideration when looking at
KRIs for developing world locations, yet don’t really feature in criteria in
the developed world. In the major financial centres, many things are
assumed, for instance, an absence of natural threats such as hurricanes or
flooding. Yet London used to have significant flood risk, and may
again as the Thames Barrier comes to the end of its projected usefulness.
Geologic issues such as earthquake-prone faults or health issues such as
malaria don’t seem to feature. Nor does terrorism risk seem strong in
peoples’ perceptions of what matters. There are also numerous personal
issues that don’t feature – work permits, opening bank accounts, arranging
for utilities, schools, personal safety – any of which could scupper a
trading floor. Somewhat naturally, people tend to care about those
things of which they are conscious. Any of a number of issues could
have us looking back several years from and grimly nodding about how trading
ceased to function when “people wanted to avoid concentrating terrorism
risk” or “infectious diseases just became too dangerous to have people so
highly concentrated”. The PKRIóLI
approach is an approach for regular management, not extreme events.
It is a combination of factors that makes a set of KRIs successful, not just
a single factor. Jared Diamond derives an Anna Karenina Principle from
the opening line of Tolstoy’s novel: “Happy families are all alike; every
unhappy family is unhappy in its own way.” (Guns, Germs, and Steel,
Random House, 1997). Diamond believes the principle describes situations
where a number of activities must be done correctly in order to achieve
success, while failure can come from a single, poorly performed activity.
This is certainly the case for KRIs – the evolving set of KRIs is important,
not a single one at a point in time, nor too many all the time.
Environmental Consistency Modelling Using Support Vector Machines
Two examples of Environmental
Consistency Confidence projects using PKRIóLI
are explained a bit later (a European Investment Bank and a Global
Commodities Firm), but it is worth looking at the support vector machine
approach that underlay the modelling. Both projects used
classification and prediction tools based on support vector machine
mathematics to undertake predictive analysis of the data. Support
Vector Machines (SVMs) are algorithms that develop classification and
regression rules from data. SVMs result from classification algorithms
first proposed by Vladimir Vapnik in the 1960’s, arising from his work in
Statistical Learning Theory [Vapnik, 1995, 1998]. SVMs are based on some
wonderfully direct mathematical ideas about data classification and provide
a clear direction for machine learning implementations. While some of
the ideas behind SVMs date back to the 1960’s, computer implementations of
SVMs did not arise until the 1990’s with the introduction of a
computer-based approach at COLT-92 [Boser, B., Guyon, I. and Vapnik, V.,
1992].
SVMs are now used as core components in many applications where computers
classify instances of data (e.g. to which defined set does this group of
variables belong), perform regression estimation and identify anomalies
(novelty detection). SVMs have been successfully applied in time series
analysis, reconstructing chaotic systems and principal component analysis.
SVM applications are diverse, including credit scoring (good or bad credit),
disease classification, handwriting recognition, image classification,
bioinformatics and database marketing, to name a few.
SVMs are said to be independent of the dimensionality of feature space as
the main idea behind their classification technique is to separate the
classes in many data dimensions with surfaces (hyperplanes) that maximise
the margins between them, applying the structural risk minimisation
principle. The data points needed to describe the classification
algorithmically are primarily those closest to the hyperplane boundaries,
the “support vectors”. Thus, only a small number of points are required in
many complex feature spaces. SVMs can work well with small data sets,
though the structure of the training and test data is an important
determinant of the effectiveness of the SVM in any specific application.
SVMs compete forcefully with neural networks as well as other machine
learning and data mining algorithms as tools for solving pattern recognition
problems. Where SVMs do not perform well it is arguable that the
algorithmic rules behind the support vector algorithm do not so much reflect
incapabilities of the learning machine (as in the case of an overfitted
artificial neural network) but rather regularities of the data. In
short, current opinion holds that if the data in the domain is predictive,
SVMs are highly likely to be capable of producing a predictive algorithm.
Importantly, SVMs are robust tools (understandable implementations, simple
algorithmic validation, better classification rates, overfitting avoidance,
fewer false positives and faster performance) in practical applications.
“The SVM does not fall into the class of ‘just another algorithm’ as it is
based on firm statistical and mathematical foundations concerning
generalisation and optimisation theory” [Burbridge & Buxton, 2001]. However,
comparative tests with other techniques indicate that while they are highly
likely to be capable of predicting, in applications SVMs may not be the best
approach for any specific dataset. “In short, our results confirm the
potential of SVMs to yield good results, especially for classification, but
their overall superiority cannot be attested” [Meyer, Leisch, Hornik, 2002].
PropheZy and
VizZy are two software packages developed by Z/Yen for classification
and visualisation of data [www.zyen.com/Products/Prophezy/prophezy.htm,
www.zyen.com/Products/Vizzy/vizzy.htm]. PropheZy implements a SVM on a
server (though it can be used in a local client/server mode). Naturally, as
in any field of computing, there are a number of variant SVM
implementations, of which PropheZy implements three types - C-SVC, nu-SVC
and binary. Further, of statistical importance in replicating results
is the “kernel function”. PropheZy implements four types of kernel function
- linear, radial basis function, sigmoid and polynomial. The SVM types
and kernel function types are described in detail in Vapnik [1995, 1998].
For this study, the SVM implementation used was C-SVC and the kernel
function was linear.
Z/Yen has benchmarked PropheZy against standardised machine learning tests,
e.g. appropriate StatLog test sets [Michie, Spiegelhalter and Taylor, 1994],
in order to validate the SVM with good to excellent results. In
industrial application, Z/Yen has trialled PropheZy extensively in financial
services applications and sees great promise for SVMs and other Dynamic
Anomaly and Pattern Response (DAPR) techniques in areas such as compliance
[Mainelli, 2005], trade anomaly detection and scorecards [Mainelli, 2004] as
well as regression and value prediction [Mainelli, Harris and Helmore-Simpson,
2003].
So far, the PropheZy server SVM has been implemented on a Linux server, a
Sun Solaris server and a Windows NT server. PropheZy implements the
user-interface to the server SVM via XML (extensible mark-up language). The
XML user-interface can be via an HTML page, directly through a bulk file
loader command line or by use of an Excel add-in that performs XML data
submission from spreadsheets to the server SVM and displays results back in
Excel spreadsheets. For this study, the PropheZy implementation was
the Excel add-in using the Windows NT server. VizZy provides
clustering, histogram, Voronoi and data cube diagrams from tabular data.
Environmental Consistency Confidence
The conjunction of SVMs with
traditional system dynamics may seem unorthodox, but it gives organisations
the capability of regularly applying scientific management. Our
hypothesis is that certain KRIs predict future losses and incidents, so
let’s test that using modern statistical tools. If our environmental
factors are consistent with the outcomes, then we can be confident we are
tracking the right things. From the fact we are tracking the right
factors, we should then develop projects to eliminate or mitigate the
causes. If we fail to predict, we are not tracking the right things
and need to explore further, and fairly rapidly as it indicates that things
may be ‘out of control’.
If we look at the wider system of wholesale financial institutions we see
similar high-level systems that can be predicted, not just operational risk.
The following diagram sets out a simple model of finance as one where risks
are selected through positioning and marketing and then priced by attempting
to ascertain the difference in value to customers and the cost of capital:

At each point in this abstract model of
finance, we can use a KRI system – marketing: can we predict sales; pricing:
can we predict profitability; underwriting/trading: can we predict incidents
and losses? A KRI system, as with any system, has basic components:
-
governance: working from the
overall objectives of the business set out a definition of the
operational risk framework, the calculation of economic capital and a
basic set of essential KRIs;
-
input: gaining stakeholder
commitment, assembling resources and appointing a team that then work to
establish the potential KRIs;
-
process: supporting the
operational risk managers through data collection, statistical
validation, statistical testing, correlations, multivariate prediction,
cross-project discussion, training, template materials and
methodologies;
-
output: evaluating KRIs,
focused on a ‘customer’ point-of-view (how does this help me manage my
business better), so that people learn from both successes and failures;
-
monitoring: providing
management information up to governors, over to customers, down to
project managers and across project managers so that they are
co-ordinated. Monitoring also uses feed-back from KRI
outcomes to feed-forward into new KRI ideas and re-plan the shape
of the KRI portfolio. An integral part of monitoring is evaluating
KRIs at a technical level – do they predict? PKRIóLI
prediction is one direction, and LIóPKRI
is another.
The KRI System is a classic feed-back
and feed-forward cybernetic system. KRIs help managers to manage by
reducing the amount of measures they need in both feed-forward and
feed-back. So the crucial distinction is between RIs and KRIs using
PKRIóLI, as KRIs
help to combat information overload:
“What information consumes is
rather obvious: it consumes the attention of its recipients. Hence
a wealth of information creates a poverty of attention, and a need to
allocate that attention efficiently among the overabundance of
information sources that might consume it.” [Simon 1971, pages 40-41]
By giving managers a clear focus on the
operational risk drivers, they can commission further work to reduce them.
The KRI system can be represented diagrammatically as:

So, in many ways, the PKRIóLI
approach is a classic system dynamics approach, but the use of the SVM to
link inputs (KRIs) with outputs (incidents and losses) focuses on
establishing predictive relationships rather than presuming that the dynamic
modelling paradigm is intrinsically important to either how those
relationships are validated or how they are interpreted.
The PKRIóLI
approach is a dynamic process, not a project to develop a static set of
KRIs. This means that a team, possibly aligned with other ‘scientific’
management approaches such as 6Σ, need to be constantly cycling through an
iterative refinement process over a time period. This leads to the
development of cyclical methodologies. Z/Yen’s
Z/EALOUS methodology is one such, and diagrammatically illustrated
below:

What Is Current Practice? - Two Early
Examples
Scientific management of wholesale
financial operations is increasing. Investment banks have increased
their operational benchmarking markedly since the late 1990’s.
Managers in many investment banks (e.g. Bank of America, JPMorganChase,
Citigroup and Merrill Lynch, amongst others, have publicly announced their
pursuit of 6Σ) follow the DMAIC or DMADV 6Σ approaches (originally from GE)
when they have losses/incidents that they want to eliminate by eliminating
root-causes:
DMAIC - Existing Product/Process/Service
|
Stage |
Objectives |
|
Define |
Define the project goals and customer (internal
and external) deliverables |
|
Measure |
Measure the process to determine current
performance |
|
Analyze |
Analyze and determine the root cause(s) of the
defects |
|
Improve |
Improve the process by eliminating defects |
|
Control |
Control future process performance |
DMADV - New Product/Process/Service
|
Stage |
Objectives |
|
Define |
Define the project goals and customer (internal
and external) deliverables |
|
Measure |
Measure and determine customer needs and
specifications |
|
Analyze |
Analyze the process options to meet the customer
needs |
|
Design |
Design (detailed) the process to meet the
customer needs |
6Σ is clearly related to a dynamic system view of the
organisation, a cycle of tested feed-forward and feed-back. This had
led to greater interest in using predictive analytics in operational systems
management. Several leading investment banks, using 6Σ programmes and
statistical prediction techniques (predicting trades likely to need manual
intervention), have managed to reduce trade failure rates from 8% to well
below 4% over three years for vanilla products. As the costs per trade
for trades requiring manual intervention can be up to 250 times more
expensive than trades with straight-through-processing transaction, this is
a very important cost-reduction mechanism, as well as resulting in a
consequent large reduction in operational risk.
Predictive analytics also feature where investment banks are moving towards
automated filtering and detection of anomalies (dynamic anomaly and pattern
response - DAPR) [Mainelli, October 2004]. Cruz [2002] notes that a number
of banks are using DAPR approaches not just in compliance, but also as
operational risk filters that collect “every cancellation or alteration made
to a transaction or any differences between the attributes of a transaction
in one system compared with another system. … Also, abnormal inputs
(e.g. a lower volatility in a derivative) can be flagged and investigated.
The filter will calculate the operational risk loss event and several other
impacts on the organisation.” He continues, “the development of filters that
capture operational problems and calculate the operational loss is one of
the most expensive parts of the entire data collection process, but the
outcome can be decisive in making an operational risk project successful.”
DAPR Support Vector Machine Example:
Contrasting a sub-set of actual versus predicted trade price bands

PKRIóLI
aligns with this interest in using predictive analytics to improve
operational management. While interest in the PKRIóLI
approach may be rising, particularly among investment banks, there has been
a paucity of data available for these purposes. As operational risk
units are growing and developing data collection and measurement systems,
PKRIóLI
projects are growing in number.
European Investment Bank
One European investment bank used three years data to
predict losses/incidents from data such as deal problems, IT downtime, and
staff turnover over a six month period. It achieved reasonable
predictive success, an R2 approaching 0.9 at times, though more frequently
0.6 (i.e. 60% of losses can be predicted). A high-level snippet gives a
flavour of the data:
|
Location ID |
1 |
2 |
3 |
4 |
|
HR-Headcount # |
136 |
121 |
23 |
30 |
|
HR-Joiners in month |
6 |
6 |
6 |
6 |
|
HR-Leavers in month |
11 |
11 |
11 |
11 |
|
IT-System Disruption Incidents |
2 |
2 |
0 |
0 |
|
IT-System Downtime |
35:07:00 |
03:13 |
0 |
0 |
|
FO-Trade Volume # |
19218 |
8999 |
661 |
4307 |
|
FO-Trade Amendments # |
317.1 |
0 |
8.7 |
80.5 |
|
OPS-Nostro Breaks # |
3 |
17 |
3 |
7 |
|
OPS-Stock Breaks # |
9 |
4 |
0 |
1 |
|
OPS-Intersystem Breaks # |
6 |
2 |
0 |
1 |
|
OPS-Failed Trades # |
463 |
26 |
0 |
7 |
|
OPS-Unmatched Trades # |
52 |
0 |
7 |
0 |
|
RIS-Market Risk Limit Breaches # |
0 |
3 |
0 |
1 |
|
AU-High Risk O/S Overdue Audit Issues # |
0 |
0 |
0 |
0 |
|
AU-High Risk O/S Audit Issues # |
4.5 |
4.5 |
4.5 |
4.5 |
Note that some of the items in this snippet, e.g. HR
joiners/leavers or IT disruption at the system level, can in practice be
very hard to obtain. It was also noteworthy that, as a data-driven
approach, PKRIóLI
projects are only as good as the data put into them – “garbage in, garbage
out”. In some areas, the data may not be at all predictive. More
rigour needs to be used as the data becomes more important. Data
quality can vary over time in hard-to-spot ways and interact with wider
systems, particularly the people in the systems. For instance, in this
trial of PKRIóLI,
the IT department was upset at IT downtime being considered a “key risk
indicator” and unilaterally changed the KRI to “unplanned” IT downtime,
skewing the predicted losses. This change was spotted when using the
DAPR system to run the reverse LIóPKRI
prediction as a quality control. Another example of Goodhart’s Law,
“when a measure becomes a target, it ceases to be a good measure” (as
restated by Professor Marilyn Strathern).
Global Commodities Firm
A large global commodities firm active not only in a
number of commodity markets but also foreign exchange and fixed income
piloted the PKRIóLI
approach in one large trading unit. While the predictive success was
not especially great in the pilot, an R2 approaching 0.5, the approach was
seen to have merit and they decided to roll the PKRIóLI
methodology out globally across several business units. It was telling
that the PKRIóLI
approach helped them to realise the importance of good data collection and
use, and to identify areas where there data specification, collection,
validation and integration could be markedly improved. It is also
important to note that the SVM approach did not add much value in the early
stages, many of the predictive relationships were straightforward, e.g.
large numbers of deal amendments can lead to later problems.
The PKRIóLI
approach has become part of a more scientific approach (hypothesis
formulation and testing) to the management of operational risk.
“Modern [organization] theory has moved toward the open-system approach.
The distinctive qualities of modern organization theory are its
conceptual-analytical base, its reliance on empirical research data, and,
above all, its synthesizing, integrating nature. These qualities are
framed in a philosophy which accepts the premise that the only meaningful
way to study organization is as a system.” [Kast and Rosenzweig in Open
Systems Group, 1972, page 47]
Conclusion
At its root, Environmental Consistency Confidence means
building a statistical correlation model to predict outcomes and using the
predictive capacity both to build confidence that things are under control,
and to improve. The correlations should raise good questions.
KRIs are a continuous, evolving system, not static, hence the focus on the
cyclical PKRIóLI
approach. Today’s KRI should be tomorrow’s has-been as managers
succeed in making it less of an indicator of losses or incidents by
improving the business. Likewise managers have to consider emerging
KRIs and validate them. Wholesale financial institutions can impress
regulators with PKRIóLI,
perhaps reducing regulatory overhead, but far more important is to use KRIs
to improve their businesses and reduce operational risk.
References
-
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Gower Street, WC1E 6BT, UK
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Cruz, Marcello G, “Modelling, Measuring and Hedging
Operational Risk”, John Wiley & Sons, 2002.
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Howitt, Jonathan, Mainelli, Michael and Taylor,
Charles “Marionettes,
or Masters of the Universe? The Human Factor in Operational Risk”
,
Operational Risk (A Special Edition of The RMA Journal),
pages 52-57, The Risk Management Association (May 2004).
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a Prime Metric: Operational Risk Measurement and Activity-Based Costing”
,
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pages 34-40, The Risk Management Association (May 2004).
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Compliance: Manage and Automate, or Die”, Journal of Risk Finance,
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Group Publishing Limited (June 2005).
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Mainelli, Michael, “Finance
Looking Fine, Looking DAPR: The Importance of Dynamic Anomaly and
Pattern Response”, Balance Sheet, The Michael Mainelli
Column, Volume 12, Number 5, pages 56-59, Emerald Group Publishing
Limited (October 2004).
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Mainelli, Michael, Harris, Ian and Helmore-Simpson,
Alan, “The
Auditor's Cross Subsidy” (statistical modelling of audit prices),
Strategic Planning Society E-Newsletter, Article 1 (June 2003). Also
published as “Anti-dumping Measures & Inflation Accounting: Calculating
the Non-Audit Subsidy”,
www.mondaq.com (19 June 2003).
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Meyer, David, Leisch, Friedrich and Hornik, Kurt,
“Benchmarking Support Vector Machines”, Adaptive Information Systems and
Modelling in Economics and Management Science Report Series, Number 78,
Vienna University of Economics and Business Administration (November
2002).
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Machine Learning, Neural and Statistical Classification, Ellis
Horwood (1994), out of print – see
http://www.amsta.leeds.ac.uk/~charles/statlog/.
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Simon, Herbert A. (1971), “Designing Organizations
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Thanks
I would like to thank Matthew Leitch, Justin Wilson, Ian
Harris, Jürgen Strohhecker, Jürgen Sehnert and Christopher Hall for helping
to develop some of the thinking behind this article, though not to claim
they agree with all of it.
Professor Michael Mainelli, PhD FCCA FCMC MBCS
CITP MSI, originally did aerospace and computing research followed by seven
years as a partner in a large international accountancy practice before a
spell as Corporate Development Director of Europe’s largest R&D
organisation, the UK’s Defence Evaluation and Research Agency, and becoming
a director of Z/Yen (Michael_Mainelli@zyen.com).
Z/Yen was awarded a DTI Smart Award 2003 for its risk/reward prediction
engine, PropheZy, while Michael was awarded IT Director of the Year
2004/2005 by the British Computer Society for Z/Yen’s work on PropheZy.
Michael is Mercers’ School Memorial Professor of Commerce at Gresham College
(www.gresham.ac.uk).
Michael’s humorous risk/reward management novel,
“Clean Business Cuisine: Now and Z/Yen”, written with Ian Harris, was
published in 2000; it was a Sunday Times Book of the Week; Accountancy Age
described it as “surprisingly funny considering it is written by a couple of
accountants”.
Z/Yen Group Limited is a risk/reward management
firm helping organisations make better choices. Z/Yen undertakes
strategy, finance, systems, marketing and intelligence projects in a wide
variety of fields (www.zyen.com),
such as developing an award-winning risk/reward prediction engine, helping a
global charity win a good governance award or benchmarking transaction costs
across global investment banks.
Z/Yen Group Limited, 5-7 St Helen’s Place, London EC3A
6AU, United Kingdom; tel: +44 (0) 207-562-9562.
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