Be Prepared
It’s coming.
By “it,” I mean the granddaddy of U.S. financial “re-regulation.” Just as The Great Depression hatched the SEC, the current downturn/crisis/recession “is about to prompt the most far-reaching renovation of the rules and institutions that regulate finance since the 1930s,” according to longtime Wall Street Journal columnist David Wessel.
OK, so what should we do about it?
I’ll tell you what we shouldn’t do: sit back and nervously wait to see what comes down the pike. It may be human nature to shift into “wait and see” mode during times of anxiety-laden uncertainty, but it pays to be prepared.
OpenPages Vice President Gordon Burnes, who also opposes the “sit and wait” strategy, believes there are a number of steps that organizations can do to prepare for pending regulatory changes. Here are his high-level recommendations:
1. Incorporate a risk-based approach to enterprise governance through a formalized ERM program involving all lines of business and levels of management.
2. Require executive management approval for acceptable risk tolerance levels and share decisions with business line managers as well as the board of directors.
3. Involve business line management in risk assessment activities.
4. Schedule systematic board-level reviews of risk exposure and performance.
5. Ensure that the risk management function reports directly to the chief executive officer rather than through the head of another functional area.
6. Establish separate risk management and auditing functions that are fully independent and adequately resourced.
7. Foster a risk-aware culture through periodic communication and education about risk policies.
8. Include risk management competence as part of a manager’s performance review.
9. Compile detailed, accurate, daily information on exposures across the organization. ###









May 30th, 2009 at 7:06 pm
Proactive is the word of the day when it comes to addressing risk management. We might feel like deer frozen in the headlights of increased scrutiny, but we can’t just wait for it to hit us.
OCEG finalized revisions to the GRC Capability Model (Red Book 2.0) in April (download at http://www.oceg.org/view/RB2), followed it up in May with the GRC-IT Blueprint that defines the various technologies that can help in GRC processes (www.oceg.org/Details/GRCTechnologyBlueprint) and next month will release the OCEG Burgundy Book which contains Agreed Upon Procedures for assessing GRC systems. All of these tools enable the steps you set out, and much much more.
It is time for organizations to use a common framework that enhances their ability to effectively and efficiently address GRC, drive risk-aware decisions, and increase transparency of information for all stakeholders. And the vastly improved ability to benchmark is just an extra benefit.
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