Risk Data and Analtyics

Very good questions. I’ve come across this as well on operational resilience and
cyber, where the challenges are similar

Some thoughts on this (also with the ex-regulator hat on):

Management bodies should acknowledge the challenge and be thoughtful around
how to address this, e.g. through training; reporting; succession planning
etc. We recently heard from a regulator that they were worried that sometimes
these topics are ‘outsourced’ to one person on the exec/ Board who
understands it, whereas they are looking for broader skills and knowledge in
the group. Again I think this is important to acknowledge, including the fact
that building those muscles take time In terms of ‘evidencing’ appropriate oversight and challenge by the Board,
when supervisors look at meeting minutes they would expect to see critical
questions being asked and a level of discussion (rather than the Board just
‘noting’ things) The quality of the materials and reports being presented to the Board is very
important, both data, but also someone bringing out the ‘so what’ and in
particular where there are areas of judgement and uncertainty, and where
there are trade-offs

The short answer is yes they should definitely be included. The group risk report is the bare minimum that should be included for a GSIB in terms of internal reports and you can go from there

Will to share some pages on the latest interpretation of the scope of BCBS239 by the ECB. A bit more expansive that the traditional industry approach but that is really going to be the new bar. We also have a full BCBS239 benchmarking database that covers 20+ banks (including most European GSIBs) and all dimensions of BCBS239 so maybe your client wants to participate in it