One of the most daunting
challenges in building a Risk Matrix may be
determining the scoring system to use for your
assessment. Then again, getting consensus between
all your stakeholders of the probability of an event
occurring or agreeing on the impact if it does
occur, can even be tougher.
Determining the exact
probability and measuring the financial impact of a
risk event is difficult, especially if that event
has never occurred. It could be said that you are
attempting to measure the un-measurable
Now consider the scoring system
in your matrix should attempt to remove subjectivity
even though attempting to measure a future event
will always have an element of subjectivity in it.
Having scoring of High, Low or Medium is most likely
not going to meet the auditors needs in the future
(even if they have approved such a rating in the
past!). If you elect to (continue to) use a scoring
system of H-M-L, then you should define a range of
what each of the H-M-L scores mean. The important
thing is to build logic into your scoring system
that will allow you can obtain easier buy-in between
your board and auditors. Removing as much
subjectivity as you can from your scoring system
will also contribute to easier buy-in from your
stakeholders (including the auditor).
You may also want to consider
using a numbering system based on 1-9 for a more
precise scoring mechanism. It will also give you
more options for your logic and usually facilitates
removing some subjectivity. Which in turn should
allow you to gain faster consensus among your
stakeholders.
Determining the probability of
an event occurring will be difficult if put in terms
of percentages. How are you going to determine and
agree that the probability of an event occurring is
8% or 9%? Therefore, consider using a probability
scoring system based upon likelihood that the risk
will occur in a timeframe (will occur in a year,
will occur in a 5 year horizon, etc). Again, easier
to gain consensus.
Determining the impact of a
risk event on an organization can also often very
difficult, even if the event has already occurred.
There are so many factors to consider, there is
operational risk, reputational risk, human factors
and numerous other risk factors. The timeframe of
the impact can also be long lasting making the
calculation of the impact even more arduous. So
instead of calculating a monetary value for your
impact scores, consider scores based upon relative
importance to a risk category to the organization.
Although it may be difficult to gain consensus of a
monetary amount, you may want to include in the
score the action if that risk occurred. Would you
handle it internally, would you need to report the
event to the board? Would you need to report the
event to an external body (like on your 10k)?
Although it may be difficult to put a dollar value
on the impact, you will most likely be able to gain
consensus of how the event would be handled,
internally versus reported to the board or beyond.
The risk probability and impact
ratings for an event help show that all risks are
not created equal, some are more important than
others. The same logic applies to controls; some
controls are more effective than others. A directive
control (policy) is not as effective as a detective
or preventative control. Automated controls are more
effective than manual controls. All these factors
need to be applied to your Control scoring system.
Lastly, you need to determine if your control is
considered best in class or potentially a meager
attempt at mitigating the risk.
Now once you have determined a
meaningful scoring system and rated all your risks,
how do you determine where to spend your limited
resources? Do you address risks with a Risk score
higher than a particular number (40 or 50 or 60)?
How do you determine that those high Risks are
adequately being mitigated? There are only a very
few risks where you can totally remove the
probability or impact of a risk event. Most likely,
you are already addressing your highest risks to
some degree. Besides, the risks that are most likely
to occur are the ones with the highest residual risk
score (after your controls are applied). This is
typically where your controls in place are less than
best-in-class. Therefore it is important that your
scoring system should not only include the
probability of a risk occurring, the impact, but
also include a scoring mechanism that includes the
controls you have in place and the response you have
in place if it does!
In conclusion, it is certainly
easier to develop a simple matrix and use scores
based on High, Medium and Low and try to convince
yourself and the auditor that you are doing the best
you can to mitigate risks. However, what you really
need to do is develop a system that will allow you
to build a better organization, not just something
that you can use to check off another box that the
task is complete.
Our Team
Our team is
comprised of experienced executives, managers and
consultants who will assist your banking
organization in the development, implementation and
execution of comprehensive risk management and
compliance strategies. From the initial passage of
Sarbanes-Oxley in 2002, Visage has provided
solutions to a client base ranging from private,
entrepreneurial companies to large multinationals.
Our Value
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Utilizing our proprietary
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compliance methodology, we tailor
comprehensive, cost-effective and flexible
solutions to our clients.
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Our solutions enhance your current business
processes, rather than adding unnecessary
overhead, thus creating measurable long-term
value.
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