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OSFI's Role
Contribute to public confidence in the financial system, and the safety and soundness of it thru supervision
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What Does Supervision Involve
- Assess safety and soundness of FRFIs
- Provide feedback
- Timely intervention
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Supervision's Primary Goal
Safeguard depositors and p.h. from loss
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Focus of Supervisory Framework
Determine impact of current and potential future events on risk profile of FRFI's
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Supervisory Framework - General Approach
- Consolidated supervision
- Relationship manager
- Principles-based supervision
- Supervisory intensity and intervention
- Board and sr mgt accountability
- Risk tolerance
- Reliance on external auditors
- Use of work of others
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Relationship Manager
Main point of contact between OFSI and FRFI responsible for overall risk assessment of FRFI (ensure up to date)
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Principles-Based Supervision
- Sound judgement in iding and assessing risks
- Determining appropriate method for risk mgt
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Supervisory Intensity and Intervention
Depend on FRFI's - nature
- size
- complexity
- risk profile
- consequence of failure.
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Board and Sr Mgt Accountability
- Ultimately accountable for safety and soundness and compliance with legislation
- Notify OSFI of issues that can have material adverse impact on FRFI
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OSFI's use of Work of Others
- Reduce scope of supervisory work
- Minimize duplication of effort.
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Key Principles For risk assessment
- Focus on material risk: be able to id all material risks
- Forward-looking, early intervention: able to estimate future condition to allow timely intervention
- Sound predictive judgement
- Understanding the drivers of risk
- Differentiate inherent risks and risk mgt
- Dynamic adjustments
- Assessment of the whole institution
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Material Risk
Risk with potential for loss to depositors or p.h.
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Understanding Drivers of Risk (for early intervention)
- Understand
- key causes of risks
- how risks may develop
- how severe
- Understanding comes from knowledge of
- business model (products, strategies, risk appetite)
- external environment
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Differentiate Inherent Risks and Risk Mgt
- Differentiate at operational and oversight levels, and
- Establish expectations for risk mgt and determine corrective actions
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Assessment of the Whole Institution
To arrive at composite view, combines assessments of - earnings and capital in relation to overall net risk from sig activities
- liquidity
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Definition of Significant Activity
A LOB, unit or process that is fundamental to business model and ability to meet business objectives
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How to Identify Significant Activities
- Org charts
- Strategic business plan
- Capital allocations
- Internal and external reporting
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How are Significant Activities Selected
- Quantitative: activity's % of total:
- asset,
- revenue,
- premium,
- net income,
- capital
- Qualitative:
- strategic importance,
- planned growth,
- risk,
- effect on reputation
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Definition of Inherent Risk
Probability of a material loss due to exposure to and uncertainty from current and future events
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Definition of Material Loss
Loss that could impair capital adequacy that leads to potential for loss to depositors or p.h.
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Categories Used to Assess Inherent Risk
- Credit
- Market
- Insurance
- Operational
- Regulatory Compliance
- Strategic
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Level/direction of risks
- Low / Moderate / Above avg / High
- Decreasing / Stable / Increasing
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How to Assess Inherent Risks for Significant Activities
Assess without regard to size of activity relative to size of FRFI and before considering quality risk mgt
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Role/Purpose of Assessing Inherent Risks
- For developing expectation for quality of risk mgt
- Higher the inherent risk, more rigorous day-to-day control and oversight
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OSFI Assesses Quality of Risk Management at 2 Levels of Control
- Operational mgt
- Oversight functions
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Operational Mgt responsibilities
- Manages activities and their risks on a daily basis
- Ensures staff understand risks and how to manage them
- Ensures effective and sufficient policies, processes and staff in managing these risks
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Primary Concern when Assessing Op Mgt
Whether capable of iding potential for material loss that activity may face and has adequate controls
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How does OSFI Assess Op Mgt of a Sig Activity
- Using work of oversight function
- Periodically validate effectiveness of day-to-day controls
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Oversight Functions
- Financial
- Compliance
- Actuarial
- Risk mgt
- Internal audit
- Sr mgt
- Board
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Oversight Functions responsibilities
- Look at risk at enterprise level and assess and manage risk
- Independent from operational mgt
- 7 oversight functions
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Definition of Net Risk
Inherent risk after mitigation by QRM
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Rating of the Importance of Net Risk of Sig Activity
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Definition of Overall Net Risk
Assessment of potential adverse impact that sig activities collectively could have: - on earnings and capital adequacy
- and hence on depositors and p.h.
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How is Overall Net Risk Derived
Net risks of sig activities are combined based on their relative importance
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How are Earnings Assessed
- Quality
- Quantity
- Consistency as a source of internally-generated capital
- Consider historical trends and future outlook under normal and stressed conditions
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Rating / direction of quality of oversight / Earnings / capital / liquidity
- Strong
- Acceptable
- Needs improvement
- Weak
- Improving
- Stable
- Deteriorating
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How is Capital Assessed
- Appropriateness of level and quality (current and future) under normal and stressed conditions, given overall net risk
- Effectiveness of capital mgt processes for maintaining adequate capital relative to risks across all sig activities
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How is Liquidity Assessed
Level of liquidity risk and quality of liquidity mgt
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Definition of Liquidity Risk
Potential inability to purchase or obtain funds to meet obligations as they come due
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Level of Liquidity Depends On
- BS composition
- Its funding sources
- Its liquidity strategy
- Market conditions and events
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Composite Risk Rating
- Assessment of risk profile, after considering assessments of earnings and capital in relation to overall net risk from sig activities and,
- Assessment of its liquidity
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Purpose of CRR of a FRFI
Used to determine its stage of intervention
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The Core Supervisory Process
- Planning supervisory work
- Execute supervisory work and update risk profile
- Report and intervention
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Steps in OSFI Planning Supervisory Work
- Prepare supervisory strategy for each FRFI
- Plan and prioritize supervisory work for
- each significant activity
- each oversight function
- Compare work effort across FRFls
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OSFI Executing the Supervisory Work and Updating the Risk Profile
- FRFl-specific monitoring
- Scans external environment and industry
- Reviews: more extensive than monitoring
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FRFI-Specific Monitoring
- Analyze financial results (by LOB and vs. peers) and any sig internal developments
- Disccuss with FRFI's mgt and oversight functions
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Definition of Credit Risk
Counterparty's potential inability of unwillingness to fully meet obligations
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Components of Credit Risk
- Loan loss/principal risk
- Pre-settlement/replacement risk
- Settlement risk
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Definition of Market Risk
Potential changes in - market rates,
- prices or
- liquidity in markets for int rates, credit, forex
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Definition of insurance Risk
Potential for claims payouts to p.h.
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Definition of Operational Risk
Potential problems due to inadequate or failed internal processes, people, or external events
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Exposure to Op Risk Results From
- Day-to-day operations (breakdown in transaction processing, fraud, IT)
- Specific, unanticipated event (CAT, court decisions)
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Definition of Regulatory Compliance Risk
Potential non-conformance with laws, regulations
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Definition of Strategic Risk
Potential inability to implement business plans and strategies, make decisions
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Oversight Function Responsibilities - Financial
- Analysis of overall and LOB/unit perf
- Analysis of major business cases to sr mgt and board highlighting matters requiring their attention
- Ensure effective financial reporting and MI system
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Oversight Function Responsibilities - Compliance
- Set policies and procedures for adhering to regulatory req'ts
- Monitor compliance with these policies and procedures
- Report compliance matters to sr mgt and board
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Oversight Function Responsibilities - Actuarial
- Evaluate design, pricing and valuation of products
- Assess reasonableness of policy liabiltity provision
- Review exposure mgt models and reinsurance programs
- Analyze stress testing results
- Report results to sr mgt and board
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Oversight Function Responsibilities - Risk Mgt
- id enterprise-wide risks;
- dev systems for measuring risk;
- set policies and procedures to manage risks;
- dev risk metrics (stress tests) and tolerance limits;
- monitor positions against approved risk tolerance and capital levels;
- report results to sr. mgt and board
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Oversight Function Responsibilities - Internal Audit
- Assess adherence to and effectiveness of operational controls and oversight incl corp gov processes
- Report on results of its work to sr mgt and board
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Oversight Function Responsibilities - Sr Mgt
- Dev business model and objectives, strategies, plans
- Dev and promote sound corp gov practices incl aligning employee compensation with LT interests of FRFI
- Execute and monitor achievement of business objectives, strategies and plans
- Ensure board is well informed
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Oversight Function Responsibilities - Board
- Review and approve
- business model and objectives, strategies and plans
- corp risk policy incl overall risk appetite and tolerance
- org and procedural controls
- Ensure
- sr mgt is qualified and competent
- principal risks are id'd and managed
- compensation is aligned with LT interest of FRFI
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Oversight Function Rating - Strong
- Characteristics exceed what's necessary, given nature, scope, complexity and risk profile of FRFI.
- Consistently demonstrated highly effective perf.
- Characteristics and perf are superior to sound industry practices
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