Capital Markets Examiner School, Providence, RI

Policies & Risk Management-Staffing and Resources

 Do they provide reasonable staffing and IT sources to risk management efforts?

 This is where size can draw distinct differences and complexity can drive needs

 However, complexity can drive needs

Policies & Risk Management

 Is there a clear and consistent documentation structure?  Policies – standards – procedures?

 Policies – board approved, high level documents that set risk appetite and delegate authority  Standards-senior management implementation of policies for key staff guidance  Procedures – the “how to” documents which describe operational processes

 Larger institutions frequently rely on the 3 layers

 At smaller institutions, the 3 layers can merge into 2 (and sometimes 1) document