Actuarial Notes

Operational Risk

Study guides: Exam 9, Exam CFE-101, Exam CP-321, Exam GH-101, Exam INV-201

Operational Risk is the risk of loss resulting from inadequate or failed internal processes, people and systems, or from external events — the Basel Committee's definition, used almost word for word in Solvency II. It includes legal risk but excludes strategic and reputational risk, and it is classified by cause: a loss is operational because of why it happened, not because of the account it lands in.

L_{\text{op}} = \sum_{i=1}^{N} X_i

E[L_{\text{op}}] = E[N]\,E[X]

  • N is the number of operational loss events in a year and X_i their severities — the loss distribution approach, the same aggregate loss model actuaries use for claims. With Poisson frequency at rate \lambda, \text{Var}(L_{\text{op}}) = \lambda\,E[X^2] (Compound Poisson Process). Internal loss data are sparse and severities heavy-tailed, so they are supplemented with external loss data and expert scenario analysis.
  • Basel's seven event types: internal fraud; external fraud; employment practices and workplace safety; clients, products and business practices; damage to physical assets; business disruption and system failures; execution, delivery and process management.
  • In an insurer these look like claims leakage and fraud, underwriting outside authority, a policy or claims system outage, a cyber attack, mis-selling or bad-faith claims handling, a data or model error in pricing or reserving, and failure of an outsourced provider.
  • Determining operational risks is mostly identification and control: process mapping, risk and control self-assessment, a loss-event database, key risk indicators that give early warning (system downtime, claim-file backlog, staff turnover), and internal controls — for U.S. public companies, the Sarbanes-Oxley regime over financial reporting. Capital regimes charge for it too: the operational risk margin in Canada's MCT, a module in Solvency II, and a component of the NAIC RBC formula.
  • It is largely incidental risk: an insurer earns nothing for bearing it, so the aim is to reduce it cost-effectively rather than to exploit it. It also tends to arrive alongside other risks — the catastrophe that floods the claims office.

Which of These Losses Are Operational? After a hurricane an insurer records: (a) \$400M of policyholder claims; (b) \$6M to restore its flooded claims centre; (c) \$15M of overpayments because emergency adjusters were given unchecked payment authority; (d) \$20M of prior-year reserve strengthening after a broken spreadsheet link is found; (e) \$25M of prior-year strengthening because construction inflation outran the assumption; (f) \$10M unrecoverable from a failed reinsurer; (g) the loss of 8\% of its renewals after complaints about slow claims service. Classify each.

Answer

  • (a) Insurance (catastrophe) risk — the risk the insurer is paid to take.
  • (b) Operational — damage to physical assets and business disruption.
  • (c) Operational — execution and process management; a control failure.
  • (d) Operational — a process error, even though it appears as reserve development.
  • (e) Insurance (reserve) risk — the estimate was reasonable; the world changed.
  • (f) Credit risk — reinsurance counterparty default.
  • (g) Strategic / reputational, outside the Basel definition — but its cause, poor claims handling, is operational, and the fix lies there.

Items (d) and (e) hit the same line of the income statement. The cause decides the category, and the category decides the remedy: controls for (d), better trend assumptions for (e).

Is the Control Worth Its Cost? Claim-payment errors occur as a Poisson process with \lambda = 4 a year; each costs on average \$250{,}000 with standard deviation \$500{,}000. A dual-authorisation control costing \$200{,}000 a year would cut the frequency to 3. Find the mean and standard deviation of annual loss before and after (in \$000).

Answer E[X^2] = 250^2 + 500^2 = 312{,}500.

\begin{align*}
\text{Before:} \quad E[L] &= 4 \times 250 \\
&= 1{,}000 \\
\text{SD}(L) &= \sqrt{4 \times 312{,}500} \\
&= 1{,}118 \\[6pt]
\text{After:} \quad E[L] &= 3 \times 250 \\
&= 750 \\
\text{SD}(L) &= \sqrt{3 \times 312{,}500} \\
&= 968
\end{align*}

The control saves \$250{,}000 a year in expectation for a cost of \$200{,}000, and cuts the standard deviation by 13\% — worth doing. If the concern were the tail rather than the mean, a control capping severity (a payment limit) would do more than one reducing frequency.