In Part I of this two-part blog, we focused on the first three components to help formalize your ERM program. They are: the Enterprise Risk Management (ERM) Risk Assessment, the ERM Policy, and the Board Risk Committee and its Charter. In Part II, we focus on the next three essential components that are also very important when formalizing your ERM Program.
Internal ERM Committee and Charter
One of the first steps in formalizing your ERM Program is to form an internal ERM Committee. One common question is, who should be on this committee? The number of members is not as important as having all the areas of the institution represented. One person can represent more than one area. Risk can come from any area of the institution so it’s crucial to protect every aspect of it. Let’s dig in deeper on the components of the internal ERM Committee Charter:
- Purpose: To assist the Board in its oversight of management’s responsibility to identify and manage existing and emerging risks at the enterprise level. This encompasses the identification, mitigation, monitoring, reporting, and management of all risks. The Committee ensures then that the processes and resources to manage and mitigate the risks identified are adequate.
- Goal: The goal is to assist the Board in understanding all the risks the institution faces as it accomplishes its vision and strategic objectives. The Committee establishes the program to help anticipate emerging risks, identify current risks, prioritize top risks, and manage all risks.
- Role of the Risk Leader: We explain the role of the risk leader in the next component below.
Dedicated Risk Leader
One common mistake community banks and credit unions make is to give the “hat” of risk leader to an already full-time employee. This employee is typically the compliance officer, BSA officer, or internal auditor. While employees with these backgrounds are excellent candidates to lead risk management, they are already overloaded with these critical functions. Often, one person already has all these responsibilities plus now they must also be the new risk officer.
Part of the Board’s “tone at the top” regarding ERM is to allocate adequate resources to it. Naming an already full-time employee with this new responsibility does not provide the appropriate resources. The result is an incomplete ERM Program and a burnt-out employee. Another significant aspect of the Board’s support of ERM is to emphasize its importance by communicating to all staff. Giving an employee the risk leader’s responsibilities without the authority that goes with the job only leads to frustration.
Lastly, new risk leaders need training. Most often risk leaders come from other areas of the institution such as the ones listed above. Risk management may be completely new to them, and they need the appropriate training and resources.
Risk Leader Responsibilities
The titles for the risk leader vary. But the most common are Vice President of Risk Management, Risk Manager, Risk Management Officer, Risk Officer, and Chief Risk Officer. Below are the responsibilities of a dedicated Risk Leader.
- The primary responsibility is to develop a comprehensive enterprise-wide program to include all the institution’s areas and ensure it’s followed. The risk leader ensures the implementation of sound policies, processes, procedures, and best practices. Risk leaders lead the effort to identify and mitigate existing and emerging risks. Lastly, they are responsible for monitoring all mitigating activities, and report on all efforts to the Board regularly.
- Chair the internal ERM Committee meetings. Ensure someone documents the minutes of the meetings and provides them to the Board.
- Create awareness enterprise wide about the ERM Program and educate all staff on its purpose and what it entails.
- Build the team as one person cannot implement nor maintain the entire ERM Program.
- If the risk leader is in the role of Chief Risk Officer, this role oversees other areas. Some of those areas include compliance, audit, IT Security Officer, CRA, collections, and fraud.
Board Risk Appetite and Tolerance Statement
There is some confusion as to what this “statement” entails. Typically, institutions write one-paragraph describing their “appetite statement” and that’s it. Very few understand the depth of this document and what it tells the reader, which is typically examiners and auditors.
The Board Risk Appetite and Tolerance Statement describes the Board’s appetite for risk and the tolerances established for each risk category. The “appetite” is the qualitative part of the statement that describes the “what,” your pursuit of risk. In other words, what products and services your institution wants to offer to your customers. It also describes what initiatives you’re willing to embark on and your level of risk appetite for every risk category.
The “tolerance” is the quantitative part of the statement that describes how much you’re willing to lose. Again, your level of tolerance for risk in each risk category. The risk categories include Credit, Liquidity, Interest Rate Risk, Technology, Operational, Reputation, HR, Compliance/Regulatory/ Legal, Model, Capital, Customer, and Earnings.
When to Start Formalizing Your ERM Program
If your institution is below $500 million in assets, examiners may only provide best practices and recommendations. They ensure you have the big components under the ERM Program. They include Cybersecurity, IT, DRP, BCM, Compliance, Audit, Liquidity Contingency Plan, Capital Plan, and Vendor Management. If your institution’s asset size is between $500 million and $1 billion, examiners will start asking you about formalizing your ERM Program. Once you reach the $1 billion asset size, you are expected to have a more comprehensive and formal ERM Program. Incorporate the six essential components to formalize your ERM Program described here, and you will be on your way.
Hopefully this two-part blog that describes the six key components to formalize your ERM Program helps you start the process. If you need help formalizing your ERM Program, feel free to reach out. As always, we’re here to help!
