Avoiding the Black Swan: Barriers to Improving Risk Management
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November 2009 Survey Results Avoiding the Black Swan: Barriers to Improving Risk Management The Unique Alternative to the Big Four®
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Avoiding the Black Swan: Barriers to Improving Risk Management Executive Summary While troubling in significant ways, these Nearly half of the survey respondents Almost daily, U.S. business journals survey results also point to important listed themselves as CFOs, while 17 have chronicled the failure of major opportunities for top executive teams to percent said their title was vice president corporations to discover, evaluate, and quickly and effectively begin assessing of finance and another 12 percent were mitigate the serious risks that have their corporate risk management and directors of finance. They were from crippled the companies and financial installing programs that will go a long companies in every major industry, from markets. The disastrous results felt way toward restoring the confidence auto, industrial, and manufacturing to throughout the economy have given of investors and stakeholders where financial services, real estate, and retail. new and sharp meaning to the dire necessary. Results need for more muscular, comprehensive Research Objectives The Biggest Challenge: Managing Risk enterprise risk management (ERM) in and Methodology The survey respondents show a corporate America. Crowe commissioned this research study heightened awareness that as the This survey from Crowe Horwath LLP, in order to determine CFOs’ perspectives business environment has become more in collaboration with CFO Research on managing risk across a number of complex and more global, new varieties Services, is particularly timely for dimensions. The study was also geared and levels of risk have been created in all corporate executives at every level. to identify how CFOs interact and types of business units. Conducted in April 2008, even before collaborate with others, including the Asked what will be “particularly the full extent of the country’s economic board, the audit committee, and chief challenging for your organization in problems was clear, this study reveals audit executives. the next 12 months,” fully 65 percent troubling barriers to excellence in The study was conducted in April said “managing risk across the entire corporate audit efficiency and risk 2008 and was answered by 157 chief company.” Slightly less than half listed management. It is hardly a reach to finance executives at a broad range of “improving financial reporting” as a suggest that the deficiencies revealed in companies across North America, with particular challenge, and 43 percent this survey could well have contributed revenues ranging from $100 million to chose “improving internal controls” to the magnitude of the economic more than $10 billion a year. (Exhibit 1). Each of these concerns, of collapse that has imperiled the country. course, is an important element of ERM. At the same time, it offers a variety of guides and lessons for improving risk Exhibit 1: The Biggest Challenges management at key corporate levels “Which of the following activities do you believe will be particularly challenging for your as the country struggles through organization in the next 12 months?” recovery and re-establishes its Managing risk across the entire company 65% economic strength. Improving financial reporting 47% Chief finance officers across the Improving internal controls 43% country, for example, revealed a Complying with regulation 34% surprising lack of understanding and support within many of their Adopting International Financial Reporting Standards 18% corporations for effective ERM. Too Developing a fraud prevention program 8% many of their C-suite colleagues, Monitoring whistle-blower process 6% they said, believe such programs are Complying with Foreign Corrupt Practices Act 5% “unnecessary” – a startling response Other 7% in light of the dismal risk assessment 0% 20% 40% 60% 80% performance of so many corporations. www.crowehorwath.com 3
Crowe Horwath LLP But if managing risk across the entire company poses the main Exhibit 2: Barriers to Change challenge for these executives, “In your opinion, what are the greatest obstacles to improving risk management at your company?” the Crowe study shows that they face daunting obstacles. Lack of time, attention, and resources 48% More than a third of the finance Perception of risk management as an unnecessary 35% executives, for example, said their interference with business activities companies see risk management Lack of shared understanding and approach to risk 35% management across business units/departments “as an unnecessary interference with Lack of dedicated risk management resources 26% business activities.” And the same percentage, 35 percent, said their Lack of tools, frameworks, and decision-making 26% structures for risk management companies showed a “lack of shared Organizational resistance 24% understanding and approach to risk management across business Lack of internal expertise 14% units” (Exhibit 2). Lack of senior management commitment 12% Nearly half of the survey respondents said that the greatest obstacle Overly complex corporate structure 12% to improving risk management at Inadequate or overly complex technology 10% and information systems their company was “lack of time, attention, and resources.” More Lack of independence of risk function 5% specifically, the financial executives Lack of strength and capabilities in the internal 3% audit function pointed to a “lack of dedicated Other 2% risk management resources,” “lack of tools, frameworks, and 0% 10% 20% 30% 40% 50% decision-making structures for risk management,” and “organizational assessing and then managing two main process existed to assess and manage resistance” as key barriers to successful categories of corporate risk: financial and operational risk. This finding is in line risk management in their companies. operational. Further and more important, with responses to another survey Twelve percent flatly pointed to “lack the survey shows that, in light of today’s question showing that companies were of senior management commitment.” corporate performance and the inability more tolerant of operating risk than Clearly there is work to do in to recognize and head off serious financial risk. developing and upgrading ERM financial risk, ERM is largely not working. Nearly half of the finance executives said across corporate America. In response to one survey question, 73 their companies were either very tolerant More than that, the survey indicates percent of the respondents, for example, or somewhat tolerant of operating risk. that these barriers to effective ERM said their companies had in place a Only 38 percent, on the other hand, said are indeed having an impact. It shows, coordinated, centralized process for their companies were very or somewhat for example, a potentially damaging overseeing financial risk, while fewer tolerant of financial risk. inconsistency on the part of companies in than half, only 47 percent, said a similar 4
Avoiding the Black Swan: Barriers to Improving Risk Management The Causes for Concern It has turned out, however, that many Exhibit 3: Causes for Concern companies were not equipped to assess “In the past three years has your company’s performance been disrupted in a substantial way by surprises in any of the following categories? In your opinion, their exposure, particularly to new which of the following categories poses a substantial cause for concern at your financial market risk. And now, as the company in the next year?” economy gradually recovers, financial executives show signs of having greater 36% Financial factors awareness of financial risk. 40% 31% Operational factors Forty percent of the survey respondents, 31% for instance, said that financial factors 29% Technology factors 40% would be a “substantial cause for 27% concern” during the next year (Exhibit 3). Market factors 44% An equal percentage was concerned Infrastructure/Physical factors 22% 13% about technological factors, such as 21% information technology systems and Management factors 27% communications problems. Only “market 21% Employee factors factors,” such as loss of customers, 31% moves by competitors, and supply and Organizational factors 19% 19% distribution chain difficulties, scored as a 15% slightly higher concern than financial or Reputational/Legal factors 11% technology factors. 14% Regulatory factors 18% Forty-four percent of those surveyed 0% 10% 20% 30% 40% 50% – and remember this was before the subprime and credit markets imploded Negative surprise in past three years – were concerned about those market Substantial cause for concern over the next year factors. Even so, when they were asked which factors had been “surprise” program would address each of to reduce business risk. Back then, disruptions of company performance, 36 these areas. 54 percent said that “more timely and percent pointed to unexpected financial Questions About Priorities accurate financial forecasting” would developments. and Execution be their highest priority. This concern The other top unwelcome surprises was a natural consequence of efforts to Timing obviously influences the outlook during the past three years? Thirty-one comply with Sarbanes-Oxley and deal of these key financial executives. Three percent said operational difficulties, with investor and regulatory skepticism years earlier, for example, a similar and 29 percent said technology had following several years of corporate survey asked them to prioritize the caused unpredictable disruptions. A scandal, starting with Enron and “most critical” needs for their companies comprehensive, companywide ERM WorldCom. www.crowehorwath.com 5
Crowe Horwath LLP The next most needed anti-risk measure, picked by 34 percent of Exhibit 4: Critical for Cutting Business Risk respondents then, was “improving “In your opinion, which of the following are most crucial to address to reduce business risk at your company?” corporate governance,” followed by “improved production” in fifth place, with only 25 percent Improved production and operating processes 41% 41% 17% identifying it as their company’s More timely and accurate financial forecasting 37% 48% 16% highest priority. Better inventory planning 23% 24% 53% In the April 2008 survey, “improved Better information security/privacy 20% 49% 32% production and operating Better enterprise software for finance and accounting 16% 41% 42% processes” moved to the top position as the most-needed anti- Improving corporate governance 12% 48% 40% risk measure, picked by 41 percent Better outsourcing strategy 10% 25% 65% of the respondents. “More timely Better management of outsourcing relationships 9% 30% 61% and accurate financial forecasting” was the number two “high priority” 0% 20% 40% 60% 80% 100% concern but now was picked High priority Moderate priority Low priority by a lesser 37 percent of the respondents (Exhibit 4). Even as the economy was headed for decline, Are they as unprepared now as they Sixty-four percent of the responding with companies across the spectrum seemingly were in 2005 to cope with finance executives described themselves having failed to anticipate weakening dramatic and unforeseeable downturns as being in the leadership role for financial conditions, these finance in their business and the economy? developing their corporation’s risk executives had shifted their priorities A substantial opportunity exists for management strategy (Exhibit 5). Sixty- from financial forecasting to improving improving across-the-board management two percent also listed the C-suite operations and production. These results and assessment of risk. More than that, executive team for this leadership role. raise serious questions about their it would be understandable if top finance These two top executive categories abilities not only to prioritize accurately executives and their C-suite colleagues outranked, by far, others that were also but also to follow through on those earlier were now looking hard for new and better listed as playing a leadership role in high-priority issues. ways of managing risk. developing risk management strategy. Would more timely and accurate financial Twenty-three percent of the respondents Who Runs the Show? forecasting have helped companies said a chief risk officer and independent If that search for better risk management avoid the 2008 credit and market risk management function had a methods does in fact develop, this survey conditions that plunged them into leadership role, for instance. Just 19 shows that the push will almost certainly recession – as well as the more general percent listed their board of directors. have to come from the corporations’ top financial collapse that followed? Can finance executives working with their they be satisfied, looking back, with C-suite colleagues and, to a slightly those improvements that were made in lesser extent, from boards of directors. their forecasting and risk assessment methodology? 6
Avoiding the Black Swan: Barriers to Improving Risk Management The survey showed that to the extent Exhibit 5: Where the Buck Stops there is any pressure to increase “What role do the following stakeholders play in developing your company’s risk resources devoted to risk management, management strategy?” that pressure comes first from C-suite management, second from the board CFO and corporate finance function 64% 28% 7% 1% of directors, and third from the board’s C-suite executive team 62% 25% 6% 3%5% audit committee. That pressure, however, Chief risk officer and independent appears to be less than intense. Only 23% 11% 8% 6% 52% risk management function 15 percent of the respondents said Board of directors 19% 25% 39% 8% 8% that their C-suite team was calling Business unit management 16% 50% 26% 5% 3% for a “substantial increase” in risk Audit committee 14% 25% 30% 11% 20% management resources. Nearly half, 48 percent, said that their top management Internal audit function 6% 23% 31% 12% 28% team was pushing instead for “some External auditors/third-party consultants 4% 16% 45% 29% 9% increase.” 0% 20% 40% 60% 80% 100% Leadership role Key contributor role Supporting role Little or no role Don’t know/Does not apply The boards, business unit managers, Who’s Managing Risk? No One? audit committee and, to a slightly Perhaps most startling, though, 52 lesser degree, internal audit team, do, percent of the top finance executives however, play important supporting indicated that either they didn’t know or roles in developing risk policy. Seventy- their “chief risk officer and independent six percent of the respondents said, risk management function” played no for instance, that their business unit role in developing strategy because their management team played either a “key” companies did not have either role. or a “supporting role” in this process. A chief risk officer who can act Sixty-four percent put their board of independently – free of influence from the directors in those key or supporting roles. top corporate power structure – and an And 55 and 54 percent, respectively, independent risk management function said their audit committee and internal are among the cornerstones of effective auditors had key or supporting roles in ERM. That position and an ERM team developing risk management strategy. that functions independently does, however, require a commitment and funding from corporate leadership. www.crowehorwath.com 7
Crowe Horwath LLP Exhibit 6: How Are We Doing? “In your opinion, how well does your company perform each of the following risk management tasks?” Incorporation of risk analysis in investment decisions 22% 36% 35% 8% Response/mitigation formulation 19% 53% 27% 1% Implementation of risk mitigation strategies 16% 51% 31% 1% Risk monitoring and reporting 16% 47% 36% 1% Risk assessment and quantification 15% 49% 34% 2% Information gathering for risk management purposes 14% 52% 33% 1% Incorporation of risk analysis in strategy setting 14% 46% 36% 4% Risk identification 13% 56% 29% 1% 0% 20% 40% 60% 80% 100% Excellent performance Adequate performance Room for improvement Don’t know/Not applicable At the same time, a hefty 37 percent C-suite colleagues were not equally Ranking Their Performance: of the top management teams in the impressed by this challenge. Only 20.5 No Applause, Please survey were asking for no or just a percent of the respondents reported that Just 21 percent of the respondents were limited increase in such resources. And their finance team would be devoting willing to say that their company was that applied to 58 percent of the boards “much greater attention” to companywide “performing well,” meaning ahead of as well. All this would seem to indicate risk management in the next 12 months. peers, in its management of business a disturbing sense of satisfaction with Even more of them, close to 26 percent, risk. A nearly equal proportion, 20 existing ERM efforts and a decided lack said that ERM would be getting “the percent, conceded there was “room of urgency toward any moves to upgrade same amount of attention.” In the middle, for improvement.” Close to 57 percent them. That lack of urgency, however, may nearly 54 percent judged that risk indicated that their company was simply no longer exist in the current economic management would receive “moderately “performing adequately.” and business climate. more attention.” This response is not When the respondents were asked to Still, although the survey showed exactly a standing ovation for more ERM rate eight specific risk management awareness – by top finance executives support, with nearly 80 percent reporting tasks the numbers were disturbing at least – that ERM was expected to be only moderately more or the same (Exhibit 6). significant corporate challenge going amount of effort. forward, it seems that their boards and 8
Avoiding the Black Swan: Barriers to Improving Risk Management More than 30 percent of the respondents Managing Risk More Effectively: animosity toward ERM, for example, declared there was “room for More Collaboration and a wrote: “Do not let pessimistic auditor- improvement” in the way their companies Companywide Approach types put you out of business by performed six of the eight tasks. And for The survey gave respondents an overcontrolling everything. Life comes the other two, “risk identification” and opportunity to provide more complete with risk. You cannot eliminate all of it. “response/mitigation formulation,” 29.5 written answers to suggest better ways Get over it!” percent and 27.5 percent, respectively, to assess and manage risk. Fortunately, this opinion did not put their companies in the “room for They saw the need not only for focusing prevail. One CFO called internal audit improvement” column. That between 36 on the financial and operational business a “key agent in spreading the word on percent and 56 percent of the finance functions more equally but also for more incorporating risk management into day- executives rated their company’s top management collaboration on the to-day activities” and which, as another performance just “adequate” in these design, development, and execution of CFO put it, “is well suited to pursue, eight important risk management ERM. Nearly 40 percent said they already unearth, and identify exposures.” One functions is hardly reassuring. have “very close collaboration” with of the CFOs emphasized the need to At the time of the survey, slightly chief compliance or risk officers, general “eliminate all adversarial relationships more than 42 percent did say that the counsels, and the heads of internal and with the (internal audit function), and, as weakening U.S. Economy “would put external audit. At the same time, though, another said, “treat (IA) as a partner, not the most strain” on risk management 27 percent admitted to having “not very as police.” processes and practices during the close collaboration” with the head of A great many of the free-form answers next 18 months. But fully half said that internal audit. And nearly as many, 26.4 also pointed to the importance of more another kind of unexpected change, percent, said they had the same distant comprehensive collaboration. “Managing “mergers, acquisitions, divestitures, relationship with their chief compliance or risk should be incorporated in the day- or organizational restructuring,” would risk officer. to-day process,” one executive wrote. pose even bigger problems. These two In their open-ended replies, the finance “It needs to be part of every decision at categories of risk, perceived then and executives urged more respect and every level – not a separate checkpoint presented as distinct, may now have collegial involvement specifically with late in the process.” Another urged become more intertwined. They now the internal auditors and their teams. colleagues to “be as deeply involved in appear to describe the single and often The replies highlight an undercurrent functional operations as possible. Timely most overwhelming challenge to present- of animosity, or at least an adversarial visibility into issues and events is critical.” day corporate financial health. relationship that is not only unnecessary “You need full collaboration from the but also destructive. One finance rest of the organization,” wrote another executive typifying an organizational respondent. “You cannot do it alone.” www.crowehorwath.com 9
Crowe Horwath LLP Finally and hopefully, these chief financial Where Are We Today? Most ERM programs do not clearly executives had little doubt that there The first three quarters of 2009 define, or completely overlook, roles are significant, crucial benefits from a continued to validate our findings. As and responsibilities for top audit, risk systematic, effective, companywide a result of Crowe’s work with clients management, and C-suite executives. risk management program. Sixty-one and discussions with others, we can Often there are no clear links between percent pointed to “fewer performance identify some of the more significant ERM efforts and broader business surprises,” and 57 percent listed “better trends today: strategies. business planning.” “More effective “Black swans” continue to loom. The executives responsible for resource allocation” was the third most While rare, major crises are extremely developing and executing ERM often often mentioned benefit, and “improved damaging and difficult to predict. have had little or no understanding ability to identify business opportunities” They usually result from interrelated of how to assess risk exposures for was fourth. Surely, corporations these risks, such as the recent combined likelihood, impact, and speed of onset. days would like to see more of those. Not economic, banking, and housing crisis. Soft issues are critical. Risk to mention one of the last mentioned, but “Silo-based” risk management management is not likely to be surely far from least important, perceived programs have proved to be effective in an organization with an benefits: “higher profits.” dangerous. They contributed to AIG’s adverse culture, inappropriate values, failed risk management efforts, for or misplaced incentives. example. Highly interrelated risks Some organizations, we believe, are should not be isolated and managed putting off the ERM journey because independently. of concern about what they might find Corporate governance – including and then have to address. business practices and ethics, Many organizations are struggling ERM, transparency and disclosure, to develop an effective monitoring monitoring, legal and regulatory, process. boards and committees, and The current economic climate has communication – continue to be diverted resources and managers’ weak or overlooked altogether. attention away from the ERM process. Risk management and compliance cannot be effective without good corporate governance. 10
Avoiding the Black Swan: Barriers to Improving Risk Management Conclusion and Finally, as noted previously, the most Recommendations basic recommendation is for more The study shows clearly that there collaboration on a risk assessment is considerable work to be done program among chief finance executives, designing, developing, and implementing their C-suite colleagues, their boards high-impact ERM programs in too of directors, and the managers of their many corporations. It highlights corporation’s operating units. There surprisingly fundamental barriers to should be a sense of real urgency, doing so, from a significant belief now more than ever, to ensure that this among top management that ERM is collaboration produces a companywide an “unnecessary interference” with approach to ERM. managing their business, to a “lack of shared understanding” within companies of the need for better risk assessment. The survey found more than half the respondents rating their company’s ability to perform major risk assessments across business units as merely adequate. At the same time, the survey points to the strong leadership roles that chief finance executives and their C-suite colleagues can have developing ERM in their organizations. Certainly, given the risk assessment mistakes that have been made and the present need to restore confidence in corporations and their management teams, there has never been a more timely opportunity. An excellent start, indicated in this study, would be the hiring of a chief risk officer and the installation of an independent risk management function in the companies that have neither. www.crowehorwath.com 11
Contact Us About Crowe Rick Julien, CPA, is a partner with Crowe Crowe Horwath LLP (www.crowehorwath.com) is one of the largest public Horwath LLP in the Chicago office. accounting and consulting firms in the United States. Under its core purpose of He can be reached at 630.586.5280 “Building Value with Values,®” Crowe assists public and private company clients or rick.julien@crowehorwath.com. in reaching their goals through audit, tax, risk and consulting services. With 25 Jonathan T. Marks, CPA, CFE, CFF, is offices and 2,500 personnel, Crowe is recognized by many organizations as the partner-in-charge of the fraud and one of the country’s best places to work. Crowe serves clients worldwide as an ethics practice with Crowe Horwath independent member of Crowe Horwath International, one of the largest networks LLP in the New York office. He can in the world, consisting of more than 140 independent accounting and management be reached at 212.572.5576 or consulting firms with offices in more than 400 cities around the world. jonathan.marks@crowehorwath.com. For more information, please contact Vicky Ludema at 800.599.2304 or vicky.ludema@crowehorwath.com. www.crowehorwath.com If printed by Crowe Horwath LLP, this piece is printed on Mohawk Color Copy Premium, which is manufactured entirely with Green-e certified wind-generated electricity. Crowe Horwath LLP is a member of Crowe Horwath International, a Swiss association. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe Horwath LLP and its affiliates are not responsible or liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and all responsibility or liability for acts or omissions of Crowe Horwath International or any other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by Crowe Chizek LLP, which is not a member of Crowe Horwath International. This material is for informational purposes only and should not be construed as financial or legal advice. Please seek guidance specific to your organization from qualified advisers in your jurisdiction. © 2009 Crowe Horwath LLP RISK8094A
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