Richard Steinberg 270004HRBG firstname.lastname@example.org | | Tags:  openpages erm risk itg it-risk coso risk-management | 0 Comments | 2,524 Visits
If you haven't already seen it, it's worth a look – The Committee of Sponsoring Organizations of the Treadway Commission just published a thought paper dealing with risks related to cloud computing. It leverages off COSO's enterprise risk management framework, speaking specifically to issues surrounding hosted services delivered over the internet. The paper is geared not to the techie, but rather to management level personnel who need to understand not only the benefits, but also the associated risks. The paper briefly outlines the many benefits of cloud computing, including greater technology value at lower cost, faster speed of deployment, common technology platforms, reduced need for support personnel and related expenditures, and environmental benefits.
Naturally, most of the focus is on the risks. These include the strategic – with lower barriers of entry for new competitors and related challenge to current business models – and dependency on cloud service providers which in turn drives legal and related risks. Others include lack of transparency, reliability and performance issues, security and compliance concerns, and elevated risk of cyber attack or data leakage. The paper also deals with issues inherent in moving to the cloud, such as the extent to which management considers the impact on the company's organization and IT and other personnel resources, noting "In many cloud scenarios, the organization no longer has complete or direct control over technology and technology-related management processes. Management must determine if it has the risk appetite for the entire universe of potential events associated with a given cloud solution as some of these events extend beyond the organization's traditional borders and include some events that have an impact on the [cloud service provider(s)] supporting the organization."
The paper also discusses cloud issues in the context of COSO's ERM Framework's eight components, outlining how each can be addressed and used in evaluating cloud computing alternatives. It provides suggestions for dealing effectively with the more significant risks, and highlights key decisions to be made by senior management – as well as responsibilities of C-suite executives – and areas on which the board of directors needs to focus its attention. If your company is already in the cloud or considering going there, the paper is worth the read.
Richard Steinberg 270004HRBG email@example.com | | Tags:  education openpages risk-analytics compliance risk-management risk | 0 Comments | 2,475 Visits
You may remember hearing about problems with the College Board, which owns the SAT, and the Educational Testing Service (ETS), which administers the tests. In the recent SAT cheating scandal the College Board and ETS were accused of having lax security and a system that failed to punish cheats. But problems go back further, when a couple of years ago the SAT has serious issues with incorrect scoring of tests. And media reports speak to extensive incorrect scoring and losing test results in England in 2008, with the UK Parliament calling their operation a "shambles." And as far back as 1983 cheating was suspected in California. For details you may want to refer to my blog posting of November 2011, which includes analysis of what the accused organizations did, or rather didn’t do, to right the wrongs.
Well, we now find another player in this industry accused of wrongdoing. Princeton Review, which provides help to students in preparing for college entrance exams and sells study guides, finds itself accused of defrauding the federal government. An arm of the company that provides after-school tutoring to students at troubled schools is said to have falsified records – including forging student signatures, falsifying sign-in sheets, and making false certifications – in order to boost payments due the company. Relevant is that the company was informed of these allegations back in 2006, but prosecutors, who are now suing, say the fraud continued as nothing was done to fix the system. For what it’s worth, Princeton Review reportedly closed its tutoring division and says most of its current management joined the company after the alleged fraudulent activity took place.
But what’s striking is how the few players comprising this industry have had serious problems – not only in allowing fraud to occur, but also in failing to act in the face of wrongdoing. And this is an industry supposedly driving high academic standards! Yes, we know academic institutions are not immune to misconduct, but we can wonder how these industry players each went so very wrong. And food for thought – do we see other industries with an inordinate number of companies experiencing widespread instances of non-compliance, fraud or other misconduct? And what does that say about the culture not only of the individual organizations, but the industry as a whole? Hmmmm.
Richard Steinberg 270004HRBG firstname.lastname@example.org | | Tags:  risk-management dodd-frank compliance openpages | 0 Comments | 2,225 Visits
As a compliance officer, you’re dealing with increased regulation and expectations, while related resources are subject to budgetary constraints. Yes, senior managements read the headlines and recognize the reputational and related risks associated with legal and regulatory compliance. But what I and others see are compliance functions having to do more, often without a commensurate increase in resources.
These observations are consistent with a recent Thomson Reuters survey of financial services companies’ compliance professionals. The survey shows that compliance officers are struggling to keep up with increasing demands of global regulation – where rapidly growing regulations and increasing responsibilities, together with limited resources and constrained budgets, are causing compliance personnel to reached a “saturation point.” A whopping 84 percent of respondents say they expect to deal with more information from regulators and exchanges this year, with almost half expecting the level to be "significantly higher." The increase is expected to come from such events as splitting of the U.K. Financial Services Authority, added regulatory power of the European Supervisory Authorities, expansion of new and existing U.S. regulatory agencies resulting from Dodd-Frank, and expanded enforcement of such regulations as the U.K. Bribery Act and the U.S. Foreign Account Tax Compliance Act.
The survey results show that compliance responsibilities and expectations are diverging from realistic capabilities. For instance, with a key objective being to coordinate with other company professionals involved with regulatory risk, over half of compliance professionals say they spend less than one hour weekly with internal audit colleagues, and one third spend less than one hour per week with legal and risk professionals. And while 70 percent of respondents expect the cost of senior compliance staff to increase this year, only 11 percent of companies expect a significant increase in budgets.
Also interesting in the statement that: “While keeping executive management informed of regulatory issues is a key part of the compliance role, more than a quarter of respondents say they spend less than one hour a week reporting to their boards. In the U.S., more than half of the companies surveyed spend less than one hour a week reporting to their boards. This raises concerns about whether executive management is being kept sufficiently informed on compliance issues.” Well, it’s not entirely clear from this as to the extent of interaction between compliance officers and senior management – one hour a week with the board may be just fine, as long as there’s significant interaction directly with executive management.
In any event, what we see is compliance departments already working at a fast pace with high efficiency, but they face risks going forward if responsibilities and resources aren’t recalibrated to be in sync.
Liz Andrews 2700041WEU email@example.com | | Tags:  risk-management risk_management risk risk-analytics financial-risk | 0 Comments | 2,014 Visits
Many of our GRC members may not be familiar with TH!NK, Algorithmics, an IBM Company’s semi-annual magazine exploring the world of financial risk management. However, the June 2012 issue has something for everyone - and is centered on the perspective that to successfully identify and respond to the economic challenges of our times, we must seek a balance between learning from the past and developing the solutions of the future.
You will find in this issue articles that seek to explore this balance between past wisdoms and new possibilities, like our cover story “Back to the Future,” which revisits capital and its role in the bank of tomorrow. In our latest “In Conversation” piece, IBM’s Brenda Dietrich serves as our first IBM contributor to TH!NK, discussing how research and new data systems are changing the way we think about information. Other articles explore some of the most pressing topics in financial services, such as the interconnectivity of risk on the Buy Side or the very real trading benefits to a bank in establishing a CVA desk. As always, TH!NK seeks to build insight and linkages across seemingly disparate realms – such as social media and financial risk management, which as you will read, may not be so disconnected after all.
I encourage you to "flip through" this valuable resource - and please visit our Discussion Forum if anything in particular piques your inte