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 Risk
Management
in Finance
Six Sigma and Other
Next-Generation Techniques

ANTHONY TARANTINO
DEBORAH CERNAUSKAS

John Wiley & Sons, Inc.

 Risk
Management
in Finance
Founded in 1807, John Wiley & Sons is the oldest independent publishing com-
pany in the United States. With offices in North America, Europe, Australia, and
Asia, Wiley is globally committed to developing and marketing print and electronic
products and services for our customers’ professional and personal knowledge and
understanding.
The Wiley Finance series contains books written specifically for finance and
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nancial advisors. Book topics range from portfolio management to e-commerce, risk
management, financial engineering, valuation, and financial instrument analysis, as
well as much more.
For a list of available titles, please visit our Web site at www.WileyFinance.com.
 Risk
Management
in Finance
Six Sigma and Other
Next-Generation Techniques

ANTHONY TARANTINO
DEBORAH CERNAUSKAS

John Wiley & Sons, Inc.

Copyright

C 2009 by John Wiley & Sons, Inc. All rights reserved.

Published by John Wiley & Sons, Inc., Hoboken, New Jersey.

Published simultaneously in Canada.

No part of this publication may be reproduced, stored in a retrieval system, or transmitted in

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Limit of Liability/Disclaimer of Warranty: While the publisher and author have used their
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For more information about Wiley products, visit our Web site at http://www.wiley.com.

Library of Congress Cataloging-in-Publication Data:

Tarantino, Anthony, 1949–

Risk management in finance : six sigma and other next generation techniques / Anthony
Tarantino, Deb Cernauskas.
p. cm.
Includes bibliographical references and index.
ISBN 978-0-470-41346-3 (cloth)
1. Financial risk management. I. Cernauskas, Deb, 1956– II. Title.
HG173.T346 2009
658.15 5–dc22
2008052035

Printed in the United States of America

10 9 8 7 6 5 4 3 2 1
 To Winkey, Peapod, and SanSan
—A.T.

To Mom for her continued support

—D.C.
 Contents

Preface xv
Acknowledgments xix

About the Contributors xxi

CHAPTER 1
Introduction 1
Organization of This Book 3
Why Read This Book? 4
Note 4

CHAPTER 2
Data Governance in Financial Risk Management 5
Introduction 5
Data Governance Center of Excellence 6
Data Governance Assessment 8
Data Governance Maturity Model 8
Best Practices in Data Governance 10
Conclusion: Next-Generation Techniques to Reduce Data
Governance Risk 12
Notes 13

CHAPTER 3
Information Risk and Data Quality Management 15
Introduction 15
Organizational Risk, Business Impacts, and Data Quality 15
Examples 17
Data Quality Expectations 19
Mapping Business Policies to Data Rules 21
Data Quality Inspection, Control, and Oversight: Operational
Data Governance 21
Managing Information Risk via a Data Quality Scorecard 22
Summary 24
Notes 24

vii
viii CONTENTS

CHAPTER 4
Total Quality Management Using Lean Six Sigma 27
Introduction 27
Performance Targets 28
Process for Excellence 30
Process Improvement 31
Summary 35

CHAPTER 5
Reducing Risk to Financial Operations through Information Technology
and Infrastructure Risk Management 37
Introduction 37
The Problem 37
Risk Source and Root Cause 42
Risk Management 43
Closing Comments 45
Global IT Standards Matrix 47
Links to IT Risk Associations and Agencies 49

CHAPTER 6
An Operational Risk Management Framework for All Organizations 53
Introduction 53
Definition and Categorization of Operational Risk 54
How Auditors and Regulators Approach Risk Management 56
How Rating Agencies Evaluate Operational Risk 57
An Operational Risk Framework for All Organizations 57
Conclusion 59

CHAPTER 7
Financial Risk Management in Asia 61
Introduction 61
Risks in Asian Supply Chains 63
Risks in Asian Financial Markets 67
Conclusion 73
Notes 73

CHAPTER 8
Doing Business in Latin America: Lessons Learned and Best Practices
for the Protection of Foreign Investors 75
Introduction 75
The World Bank Indicators 76
Protection of Debt Investors 79
Protection of Minority Owners 82
Conclusion 85

CHAPTER 9
Mitigating Risk Exposure in Transitioning to the IFRS 87
Introduction 87
Revenue Recognition Risks (IAS 18) 90
Contents ix

Derivatives (IAS 39) and Hedging Risks 91

Share-Based Compensation and Pension Risks 93
Nonfinancial Asset Risks 94
Off-Balance-Sheet Risks (Financial Assets) 94
Tax Liability Risks 96
Other Liability Risks 96
Financial Liabilities and Equity Risks 97
Business Combination Risks (Mergers and Acquisitions) 97
Financial Services Industry Risks 99
Conclusion: Suggestions to Reduce the Conversion Risks 100
Notes 101

CHAPTER 10
Quantitative Operational Risk Management Methods 103
Introduction 103
Operational Risk Overview 105
Quantitative Methods 106
Modeling Approach Operational Risk 107
Operational Value at Risk 107
Multifactor Causal Models 108
Regime Switching Models 109
Discriminant Analysis 110
Bayesian Networks 111
Process Approach to Operational Risk 111
Business Process Modeling and Simulation 111
Precursor Analysis in Operational Risk Management 112
Agent-Based Modeling 113
Six Sigma Approach to Quality and Process Control: Failure
Modes and Effects Analysis 113
Conclusion 115
Bibliography 115
Notes 116

CHAPTER 11
Statistical Process Control Integrated with Engineering Process Control 117
Introduction 117
Control Schemes 118
Statistical Process Control 119
Engineering Process Control Systems 121
Finance Example 125
Conclusion 130
Bibliography 130
Notes 130

CHAPTER 12
Business Process Management and Lean Six Sigma:
A Next-Generation Technique to Improve Financial Risk Management 131
Background 131
Historical Perspective 133
x CONTENTS

BPM in Financial Services—Functionality to Look For 134

Survey of Cross Industry Deployments of BPM Solutions 135
Benefits of BPM over Traditional Process Development 136
Pulte Mortgage Case Study 136
Ameriprise Financial Case Study 136
Lean Six Sigma’s SIPOC Approach to BPM 137
Conclusion 139
Notes 142

CHAPTER 13
Bayesian Networks for Root Cause Analysis 143
Introduction: Risk Quantification in Finance 143
Causal Knowledge Discovery 144
Bayesian Networks 147
Conclusion 151
Bibliography 151

CHAPTER 14
Analytics: Secrets to Deriving Business Value and Insights
out of Information 153
Abstract 153
Introduction 154
Information Technology and Service Evolution 155
Information Analytics Technology Landscape 156
Future Analytics Technologies 166
Conclusion 167
Notes 167

CHAPTER 15
Embedded Predictive Analytics: Transforming Risk Management from
Review Function to Competitive Advantage 171
Introduction 171
Execution Risk in the Financial Services Industry 171
Business Processes 172
Predictive Analytics: Technology-Enabled Analytic Methods 173
Conclusion: Managing Risk Competitively 180

CHAPTER 16
Reducing the Financial Risks in Litigation and Legal Discovery 183
Background 183
The Sedona Conference and the New Rules of Civil Procedure 184
U.S. Court Rulings under the New FRCP 189
U.S. Rulings Impacting Businesses Outside the United States 192
Best Practices and Next-Generation Techniques 193
Conclusion 195
Notes 195
Contents xi

CHAPTER 17
The Circle of Trust 197
Introduction 197
Is Three Sigma Good Enough? 198
Economic Value of a Sigma 199
The Six Sigma Audit 200
Conclusion 202
Notes 202

CHAPTER 18
Reducing Liability Risk through Best Environmental Practices 203
Introduction 203
The Economy and the Environment 205
Environmental Risks: Risks and the Securities and Exchange
Commission (SEC) 206
Impact of Industrial Environmental Management on Firms
Competitive Advantage 208
Shift in Industrial Ecosystem toward Sustainability 210
Industrial Profitability and Sustainable Development 212
Pollution Trading and Firms Financial Performance 214
Conclusion 215
Notes 215
Bibliography 218

CHAPTER 19
Beyond Segregation of Duties: Next-Generation Techniques in
Evaluating User Access Control Risks 219
Introduction 219
User Access Controls, Not Just Segregation of Duties 219
Risk Assessment Methodology 220
The Next Generation of Segregation of Duties: User Access Controls 221
Current State and Future Direction of Risk Advisory and Audit Firms 227
Current State and Future Direction of ERP Software Vendors 230
Conclusion 231
Notes 232

CHAPTER 20
Transaction-Based Cross-Enterprise Risk Management 233
Overview 233
Background 234
Basel II and Current U.S. Implementation 235
Current State of Enterprise Risk Management 236
Financial Accounting versus Risk Accounting 240
10 Principles of Effective Enterprise Risk Management 240
A Transactional Approach 241
Cross-Enterprise Solution 244
Predictive Risk Models 250
Conventional Solutions versus Cross-Enterprise Process 251
xii CONTENTS

Conclusion 254
Notes 255

CHAPTER 21
Throughput Accounting 257
Background 257
The Five Focusing Steps 258
Throughput Accounting 259
Elements of Throughput Accounting 260
Evaluating Financial Decisions 261
Role of a Constraint 262
Applying T, I, and OE to Traditional Business Measures 263
Product Cost—Throughput Accounting versus Cost Accounting 264
Analyzing Products Based on Throughput per Constraint Unit 266
How Can a Company Increase T/CU? 268
Key Decisions Areas to Apply Throughput Accounting 269
Summary 270
Appendix: Common Questions and Answers 271
Notes 272

CHAPTER 22
Environmental Consistency Confidence: Scientific Method in Financial
Risk Management 273
Introduction 273
Paradigms Applied—Values, Control, Reengineering, and Costing 275
Environmental Consistency Confidence—Statistical Head,
Cultural Heart 276
What Is a Key Risk Indicator (KRI)? 277
Case Study: Global Commodities Firm 278
Predictive Key Risk Indicators for Losses and Incidents
(PKRI
LI) Issues 280
Case Study: European Investment Bank 280
What Is Current Practice? 283
Bigger Canvases for Scientific Management 285
Conclusion 286
Bibliography 287
Notes 287

CHAPTER 23
Quality in the Front Office: Reducing Process Variation
in Trading Firms 289
Introduction 289
Development Methodology for Quantitatively Driven Projects
in Finance 290
Waterfall Process for Continuous Improvement (Kaizen) 296
Conclusion 296
Notes 296
Contents xiii

CHAPTER 24
The Root Cause of the Global Financial Crisis and Corporate Board
Reforms to Prevent Future Failures in Risk Management 299
Introduction 299
Background to the Global Financial Crisis of 2007–2009 299
Why This Crisis Deserves Close Scrutiny 300
The Root Cause of Catastrophic Failure in Financial Risk
Management 301
How to Prevent Future Failures in Financial Risk Management 303
Conclusion 318
Notes 319

Index 321
 Preface

ccording to the Book of Genesis, God decided to destroy the world in a great
A flood because of mankind’s sinful and wicked ways. But God knew Noah was
a righteous man and decided to spare him and his family. He instructed Noah to
build an ark, a very large vessel of no economic or recreational value, to hold Noah’s
family and representatives from the animal kingdom. While there was no business
case or quantitative or qualitative risk model to justify this endeavor, Noah decided
to mitigate his risk and build the ark. We can imagine that conventional wisdom
of the time condemned Noah for such a foolish waste of time and money and that
community and media reaction would have been very negative as well.
Noah’s risk mitigation proved to be quite timely as conventional wisdom and
traditional risk management failed in a catastrophic manner. Noah survived the great
flood and began rebuilding civilization after the waters of the great flood receded.
Some time later, Toyota, a Japanese car manufacturer, decided to build a hybrid
car to mitigate the risk of rising fuel prices and need to curtail greenhouse gases.
As with Noah, there was no valid business case or accepted risk model to justify
such a foolish waste of time and money. Conventional wisdom of the time was that
large gas-guzzling vehicles were the safe choice. They were all the rage and generated
very high returns. Fuel-efficient cars were much less profitable and lacked the status
and prestige of larger and more muscular vehicles. As with Noah, we can imagine
industry leaders making fun of such a wimpy car that would appeal only to a small
number of tree-hugging environmentalists on the American West Coast.
Again, conventional wisdom and traditional risk management failed in a cata-
strophic manner. The energy crisis and push for green energy made the little hybrid
car a huge success and helped propel Toyota into a leadership position as the
most profitable and best-capitalized manufacturer in the industry. Conversely, their
American competitors are now on the verge of bankruptcy and capitalized below
their World War II levels.
A few years ago, Wells Fargo decided that the risk inherent in the subprime mort-
gage market was unacceptable, and minimized their exposure. Again, the conven-
tional wisdom and accepted quantitative and qualitative risk models argued against
their conservatism. Profit margins for subprime mortgages, mortgage-backed securi-
ties, and credit default swaps were much higher than the more traditional vehicles and
instruments offered by banks. Government regulators, rating agencies, and business
media all promoted the subprime market, either directly or indirectly. This created
shareholder pressures to jump into this very lucrative market. As with Noah and
Toyota, media and public reaction was negative to Wells Fargo’s conservative ap-
proach to risk mitigation. As with Noah and Toyota, we can imagine industry leaders
making fun of a bank with a stagecoach as a corporate symbol—too sentimental and
old fashioned to grasp the huge profit potentials in subprime.

xv
xvi PREFACE

Once again, conventional wisdom and traditional risk management failed in a

catastrophic manner. Wells Fargo not only survived the global crisis, but substantially
expanded its market position. Those who embraced subprime and its related products
have been forced out of business or critically wounded. Their subprime activities have
brought about the greatest financial crisis since the Great Depression of the 1930s.
Unlike Toyota, their failures in risk management negatively impacted the global
economy.
Our three parables demonstrate that risk management is never as easy or pred-
icable as conventional wisdom would lead one to believe. Each catastrophic failure
in risk management brings greater focus on the need for more innovative and effec-
tive techniques for risk management. Unfortunately, memories are short, and new
opportunities continue to arise and overwhelm sound risk management.
Financial risk management is especially challenging. Today’s financial products
and markets are too complex and opaque for the regulatory structures, audit prac-
tices, rating agencies, and risk management in place to oversee and control them.
Business and accounting schools struggle to keep pace in their curricula with such
a dynamic market. Government regulatory structures, designed in the Great De-
pression, were particularly ineffective in grasping the danger that very complex and
highly leveraged financial products presented not just to the banking industry but to
all of society. Rating agencies never predicted the collapse of firms, even when the
evidence became obvious. Auditors who focused on tactical internal controls regu-
lated under the Sarbanes-Oxley Act failed to grasp the systemic risks that financial
services faced.
Noah, Toyota, and Wells Fargo share some important characteristics. All three
defied conventional wisdom and public pressure to pursue major opportunities—for
an immoral lifestyle during Noah’s time, for big gas-guzzling cars during Toyota’s
time, and for subprime mortgages during Wells Fargo’s time. All three did the morally
and ethically correct thing: Noah led a righteous life, Toyota helped to fight green-
house gases, and Wells Fargo declined to market loans that eventually cost millions
of borrowers their homes. Each also utilized risk management in a unique manner
as compared to their peers that provided a strategic competitive advantage. Staying
alive in the case of Noah and prospering economically in the case of Toyota and
Wells Fargo.
Financial risk management applies a systematic and logical approach to uncer-
tainties in operations, reputations, credit, and markets. Without risk management,
an organization would simply rely on luck to avoid disasters. Financial risk manage-
ment as a discipline has progressed since the pivotal year of 1921, when Frank Knight
published his Risk, Uncertainty and Profit and John Maynard Keynes published his
A Treatise on Probability. Knight pioneered the notion that uncertainty, which can-
not be measured, is different from risk, which is measurable. Keynes pioneered the
mathematical and philosophical foundations to risk management. Keynes argued for
a greater reliance on perception and judgment when considering probabilities and
warned of an overreliance on numbers.1,2,3
In 1956, Russell Gallagher published his “Risk Management: A New Phase of
Cost Control,” in the Harvard Business Review. As an insurance executive, he argued
that a professional insurance manager should also be a risk manager. Because of the
nature of its business, the insurance industry was the first to embrace professional
risk management with its concern for avoiding unaffordable potential losses. This
Preface xvii

leadership continued into the 1960s and 1970s when the Insurance Institute of Amer-
ica developed a certification examination and designation process for an “Associate
in Risk Management,” and when insurance executives formed the Geneva Associa-
tion, which advocated the links among risk management, insurance, and economics.
In the 1980s, new risk societies were created to promote risk management—the
Society for Risk Analysis in Washington, and the Institute for Risk Management in
London. Their efforts have made the concepts of risk assessments and risk manage-
ment well understood in business and government circles.
In the 1990s, the United Kingdom’s Cadbury and Turnbull committees issued
reports advocating that corporate boards take responsibility for setting risk man-
agement policies, for assuring that the organization understands all its risks, and for
accepting oversight for the entire process. It was also in the 1990s that the title chief
risk officer (CRO) is first used by GE Capital to describe a manager who is respon-
sible for the totality of risk exposure to an organization. Chief risk officers and risk
managers are now commonplace in the financial services industry and spreading into
other industries.
The global financial crisis of 2007–2008 begs the question, with all the progress
in risk management, why were the world’s leading financial services firms, their
regulators, their auditors, and their rating agencies so wrong in their assessment of
the inherent risks in the subprime mortgage market? These organizations possessed
the most sophisticated risk management processes and technologies in the hands
of the best-educated and trained risk managers. We believe that part of the rea-
son was that they have not deployed the next-generation techniques we provide
here. These techniques could have helped to reduce the pain of the current crisis,
and provide risk, business, and IT managers with tools and solutions to substan-
tially improve their risk mitigation. There have always been leaders such as Noah,
Toyota, and Wells Fargo, who innovated in their risk management. Hopefully, our
suggestions and recommendations will help your organization become innovators as
well. As the current global crisis and our three parables demonstrate, this can mean
much more than providing a strategic advantage. It can mean the survival of an
organization.
The problem with risk management can be summarized in the teachings of the
legendary Samurai master swordsman Miyamoto Musashi, in his Book of the Five
Rings. Musashi won over 30 duels and warned to never take too hard a focus on
the point of your opponent’s sword. While this would seem to be the obvious point
of attack and the greatest risk, the attack always comes from some other point.
Therefore, a swordsman must maintain a soft focus to look at the entire field of
view. Risk is like this. The biggest threats never come from the most visible point of
attack. This was true for Noah’s neighbors, Toyota’s fellow carmakers, and Wells
Fargo’s fellow banks.
This is my third book for John Wiley & Sons targeting governance, risk, and
compliance. The three books are written as a series and designed to complement
each other:

The Manager’s Guide to Compliance focuses on the basics of compliance with

overviews of best practice frameworks, governance, and audit standards.

Governance, Risk, and Compliance Handbook focuses on the largest economies,
regions, and industries in the world as to their corporate, environmental, and
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