Just as 9/11 was more of an intelligence failure rather than a security lapse, the subprime debacle is a risk management breakdown, not merely a regulatory shortcoming. To do anything useful with this rather obvious insight, we need to understand why risk management failed, and how to correct it.
Risk management should be our first line of defense — it is a preventive mechanism, while regulatory framework (which also needs beefing up) is a curative, reactive second line.
The first reason for the inadequacy of risk management is the lack of glamour the risk controllers in a financial institution suffer from, when compared to their risk taking counterparts. (Glamour is a euphemism for salary.) If a risk taker does his job well, he makes money. He is a profit centre. On the other hand, if a risk controller does his job well, he ensures that the losses are not disproportionate. But in order to limit the downside, the risk controller has to limit the upside as well.
In a culture based on performance incentives, and where performance is measured in terms of profit, we can see why the risk controller’s job is sadly under-appreciated and under-compensated.
This imbalance has grave implications. It is the conflict between the risk takers and risk managers that enforces the corporate risk appetite. If the gamblers are being encouraged directly or indirectly, it is an indication of where the risk appetite lies. The question then is, was the risk appetite a little too strong?
The consequences of the lack of equilibrium between the risk manager and the risk taker are also equally troubling. The smarter ones among the risk management group slowly migrate to “profit generating” (read trading or Front Office) roles, thereby exacerbating the imbalance.
The talent migration and the consequent lack of control are not confined merely within the walls of a financial institution. Even regulatory bodies could not compete with the likes of Lehman brothers when hunting for top talent. The net result was that when the inevitable meltdown finally began, we were left with inadequate risk management and regulatory defenses.
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- House of Cards