Intelligent Risk: Knowledge For The Prmia Community
Intelligent Risk: Knowledge For The Prmia Community
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VO L U M E 2 , I S S U E 4 O C TO B E R 2 0 1 2
PRMIA LEADERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
Board of Directors
W
e have all heard the old adage that significant changes come in sets of
three. Prudent risk professionals, of course, know that no such link exists
among independent events, and thus tend to pay no heed to them. Yet,
for this issue of Intelligent Risk (iRisk), I must point out that there have been exactly
three changes made to the editorial board.
First, Carol Alexander has completed her tenure as executive editor. Second, PRMIA would like to welcome Andy
Condurache as the new director of exams and publications. Third, I have agreed to step in as the new editor of
Intelligent Risk, replacing Michael Martin — whom, I hear, is irreplaceable — but I will certainly try my best to fill his
shoes. Best wishes to outgoing members of the editorial team, and good luck to the new team.
One aspect of iRisk that has remained unchanged is the high quality of submissions from PRMIA members and
the risk community-at-large. The current issue features another diverse selection of risk topics from academics,
investment bankers, researchers, and even a central banker. Here is a sample:
■ Banks, bank regulators, and even politicians have spent considerable time and effort (and more than a bit
of lip service) on the stress testing of banks to alleviate systemic uncertainty. But, what about reverse stress
testing, i.e., beginning with the assumption of business failure, and working backwards through the
conditions that would lead to such failure? Two researchers from Moody’s Analytics, Juan M. Licari, and
José Suárez-Lledó, explain the concept and offer a real-world example from the U.K.
■ Implementation of Basel III provisions, while imminent, has thus far left many unanswered questions in the
minds of risk managers. For example, the calculation of the liquidity coverage ratio (LCR) is fairly
straightforward. Yet forward LCR projections, which are not mandatory but would seem to be important
exercises to undertake nonetheless, will require extra thought. Liquidity Risk’s Robert Fiedler takes a look
at how such a process may be structured.
■ Jonathan Howitt takes us on a journey through the history of inherent risk assessment and asks whether
we are truly better off than we were 20 years ago. You may be surprised at the answer.
■ William Mason, who heads the risk department at the Central Bank of Ireland, walks us through the design,
planning and implementation of PRISM, its new risk-based supervision software suite.
■ And, finally, in this month’s PRMIA chapter report we see that, whether one is a tourist or a risk manager,
there is FUN in the Philippines.
In closing, I would like to thank the PRMIA production team for allowing me the opportunity to be a part of this
fine publication. I would also like to thank outgoing editor Michael Martin, not only for his dedicated service to
PRMIA, having edited Intelligent Risk since its inception, but also for imparting me with a few kernels of wisdom
regarding the editorial process. Happy reading!
Douglas Ashburn is a Sustaining Member of PRMIA and a self-proclaimed “trader-masquerading-as-a-journalist.” Doug is a 20-
year veteran derivatives trader and manager of portfolio risk, whose focus has been in foreign exchange options, futures and OTC
derivatives. He is currently Editor-at-Large of John Lothian News, a Chicago-based financial media company, where he regularly
writes a column on FX, edits a managed futures newsletter, and leads the development of MarketsReformWiki, a site dedicated to
tracking and archiving of all information related to global financial regulatory reform.
2 INTELLIGENT RISK E D I TO R ’ S N OT E
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EDUCATION CONTINUUM
S
ome argue that hindsight is an exact science while others say that it plays tricks
on our minds. In truth, like so many of the regulations being debated today,
hindsight is a double-edged sword. It is, however, difficult to argue with the fact
that, pre-2007, the financial sector suffered from hubris. The industry had embraced the
science that was proving it right, but had forgotten the assumptions behind the models.
For this reason, we were always of the opinion that a good risk manager needs to be in strong command of
mathematical skills, and have such skills instilled through the PRMTM designation. This is true not because
quantification is the solution to everything, but rather because the understanding of models and their limitations can
only lead one to the path of informed decision-making.
Ever since Pascal and Fermat bred the theory of probabilities, we have attempted to measure risk. Finance,
however, is a bit different from the physical sciences, where the fundamental constants are exactly that — constants.
The law of gravity has not changed, nor is such a change expected any time soon, whereas the risk premium in finance
has always been the subject of controversy. In addition, the gravity of finance — volatility — actually has its own
volatility. Other factors such as geographical and social mobility are different across the sphere and in perpetual
motion. The worldly atoms, humans, do not move in a Brownian fashion, but we think, often in quite irrational ways.
If these were the physical laws of the universe we inhabit, we would probably experience a “big bang” every ten years,
if not every day.
Richard Feynman would be much more critical of the social sciences, but I think we are worthy of the chance. If
we can only find the missing common sense, and uphold the trait of epistemological humility in the face of
complexity, we will have proven that social sciences are of great value to society. Humility opens us up to learning
about changing paradigms, and we have all witnessed the shattering power of the status quo.
Fortune favors the prepared. As an analogy, Michael Phelps set a world record at the Beijing Olympics in 2008
with a goggle malfunction that effectively blinded him for the second half of the race. He could not have won without
possessing his own “recovery and resolution plan.” In order to prepare for such a potential mishap, Phelps always
conducted a portion of his training in the dark to simulate a “blind swim.”
Similarly, a champion risk manager must think about risk in an integrated fashion. She must be able to tackle the
multi-faceted nature of risk management with tools, knowledge, experience and a holistic understanding. This is
especially true in a crisis scenario when time, a precious commodity otherwise, is worth exponentially more.
PRMIA is all about being open-minded relative to risk management. We try to keep our members continually
informed about the latest developments in the field, with chapter events, webinars and publications. We have created
the world’s first budget sensitive continuous professional development program with the corporate membership. This
reflects the new reality in which management, and implicitly risk management, will be a combined top-down/
bottom-up process where we create virtuous informational feedback loops to aid in the decision-making process.
Please take a moment to review our program and consider steering your institution in this direction.
Webinars remain the core educational resource within the corporate membership. In past webinars, we have had
the honor of hosting risk management luminaries including Nobel laureates, practitioners, researchers, regulators
and consultants.
We believe that an increased sense of community will lead to the advancement of the profession, just as a country
that opens its economy and migrates towards inclusive institutions lifts its people out of poverty.
Please join us in our endeavor to reduce systemic risk and increase the social role of banking. That is a bond that
will pay in perpetuity. I would like to thank all past, present and future PRMIA volunteers for their wonderful ideas and
sustained effort in making such progress possible.
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ANNOUNCEMENTS
C ongratulations to the newly elected Board members, all of whom were elected to 3-year terms. Thank you to the
PRMIA members who voted in this year’s election.
Faruk Patel Thank you also to all of this year’s nominees. We look forward
Manager, Investment Risk, Alberta Investment to their continued participation and leadership.
Management Corporation (AIMCo)
O ne of the provisions of Basel III, the Liquidity Coverage Ratio (LCR), sets a bank’s potential cash outflows in rela-
tion to its capacity to counterbalance them by creating hypothetical inflows from assets which are believed to be
repoable or saleable. The implementation of the LCR in a bank seems to be a straightforward exercise, which can some-
how be seen as decoupled from the more sophisticated internal models a bank might use to economically manage its
funding liquidity. If, however, a bank wishes to manage the LCR not only monthly and in retrospective — as mandatory
in Basel III — but on an on-going, forward-looking basis, it will need to simulate its future balance sheet. This is already
very near to economic risk management techniques.
The LCR — Liquidity Coverage Ratio Today the bank’s assets will, by definition, match its liabilities
In the LCR the bank’s total net cash outflows of the first 30 calendar [1]. Going forward in time, assets and liabilities will not mature
days are cumulated in time and compared with the stock of “high- uniformly. If tomorrow’s maturities include more liabilities than
quality liquid assets” (“HLA”). The term “HLA” is used in Basel III with assets, the bank has a negative liquidity mismatch because there
two distinct meanings. First, it describes all unencumbered and non- are more outflows from liabilities than inflows from assets; if fewer
rehypothecated assets of the bank presumed to be easily and quickly liabilities mature than assets, the bank has accordingly a positive
converted into cash without generating substantial losses. Second, it liquidity mismatch. Negative mismatches, however, can only exist
means the amount of liquidity that can be created by liquefying the as forecasts but not in reality as the central bank will cease
HLA within a fixed time horizon of 30 days. The HLA fall into two payments on the bank’s nostro before it ‘turns negative’. Therefore
categories: level 1 assets and level 2 assets; the latter can comprise the bank must ensure that it will be able to create at least enough
up to 40% of the stock. liquidity to counterbalance the forecasted cash deficit. In the LCR,
a qualified asset (HLA) results in a cash inflow by simply
The Total Net Cash Outflows multiplying its available amount with its market price (which may
Total Net Cash Outflows comprise all expected cash flows derived be diminished by a required haircut).
from the outstanding balances of the bank’s assets; respectively
liabilities or off balance sheet (OBS) commitments which mature Lacking Term Structure of the LCR
within 30 days, multiplied with expected run off/draw down rates. In an economic liquidity risk view (the Forward Liquidity Exposure,
The construction of the net cash outflows reflects the fact that or “FLE”), on each day of the time horizon, all forecasted cash
inflows are not under the control of the bank and are thus more inflows and outflows are netted and carried forward to the next
insecure than cash outflows: day’s FLE. In practice, the FLE can fluctuate from day to day and
net cash outflows = outflows – min{inflows; 75% of outflows} thus the minimum balance will not necessarily occur on the last
day. Contrarily, in the denominator of the LCR the maturing cash
The Ratio as an Inequality flows are summed in a way such that:
The LCR is formulated as: (outflows – min{inflows; 75% of outflows})
stock of highly liquid assets which enforces that the resulting net flows are outflows. Consequently,
>100%
total net cash outflows over the next 30 calendar days the forecasted nostro balance descends monotonously until on the
last day of the time horizon the worst balance appears.
Because inflows and outflows are positive numbers the inequality The LCR’s numerator consists of those hypothetical inflows that
can also be written as: stem from an assumed liquification of the HLA assets within 30
stock of highly liquid assets > total net cash outflows days. It is unclear how quickly the assets are to be made liquid, as
the model specifies only what happens on the last day. Since we do
Complying with the LCR requires a balance sheet structure from
not know what happens inside the time horizon, it is left unclear
banks in which potential cash needs within the first month can be
whether the inequality actually holds during the time horizon, and
covered by the liquidity generated by liquid assets. The LCR can
thus whether the liquidity generating ability of the bank has
also be interpreted as a survival period of at least 30 days.
exceeded its forecasted cash needs on each day.[2]
LCR — First Considerations
Static Run-off View — But Hypothetical Transactions
The LCR is specified as a mixture of a balance sheet view and cash
Only existing assets or liabilities are to be considered when
flow view. The complete set of a bank’s transactions — assets,
forecasting the cash flows for the LCR; not yet existing liabilities or
liabilities and OBS commitments — is transformed into a sum of
assets are not regarded. To determine the counterbalancing cash
cash outflows and inflows at the end of the considered time horizon.
inflows, no explicit assumption is made regarding the repoability
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and/or salability of the HLA. How can an asset be turned into cash to TNCO(t0) := N0+N1+ ... +N30.
without selling or repoing it? Assets (liabilities) which have been
If we extend the calculation of the Ax, Lx, and Nx until tx = t0+30d
generated e.g. yesterday and will only be paid (received) tomorrow
we get the Forward TNCO(tY) = NY+NY+1+ ... +NY+30.
will create ‘future’ outflows (inflows) from today’s perspective;
there is, however, no such concept of ‘forward’ transactions in
Normal and Forward LCR
the LCR.
The result is:
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VISIONS OF RISK THOUGHT PIECES FROM PRMIA LEADERS
Not me, I am afraid. It is not only spurious math, but it is also the to each business area that contributed.
wrong approach. Let us use a simple analogy to demonstrate why. That certainly does not mean we should not be doing bottom up
Pretend you have decided to learn to drive a racing car. You should risk assessment. Quite the contrary — no sensible manager would
already be aware of the inherent risk. If the racing car had no ever want to be blind to the risks in his processes. However, we
controls, such as brakes or steering, for instance, you would not need to be pragmatic about the qualitative and, frankly, often
drive it, would you? Thus, it becomes a fairly worthless discussion subjective nature of such assessment, especially if conducted on
to quantify the inherent risk — we all know the answer is death. In an inherent and residual basis, where there is typically little or no
the same way, no business can operate without controls, so we sophistication in the quantitative methodologies deployed. We
must assume the controls are in place when assessing risk. But we should use bottom up risk assessment for management purposes
can still consider single or multiple failures, for example, what and extract the risk issues and remediation lessons, but we should
would happen in your racing car if the steering fails at 120mph on not get too bogged down on control benefit calculations or capital
a sharp turn? What if the brakes fail at the same time? How often allocations.
might that happen in 10,000 laps? We can ask the same questions
in the business context to understand tail risk: for instance, what if Self-Assessment and the Fifth Amendment
your payment reconciliation process fails during a period of high I think it was in 1993 that I was required, as a business controller,
volumes. In addition, what if your IT system fails at the same time? to complete a new FDIC internal assessment on behalf of the
Based on experience, how likely is that over any ten-year period? business. It made sense from the regulator’s perspective: since
Let us now assume we have actually had a useful risk discussion they did not always have the resources available to audit, they
with business management and we have avoided all the flawed could require firms to complete their own self-assessments.
pseudoscience and pitfalls around trying to quantify inherent and Granted, it established a moral hazard for the firm, but it provided
residual risk, and we have computed the value of the control the regulator with a starting point if a direct review was required
environment across hundreds of individual processes. Let us later. Of course, many of us in large firms have regularly had to
assume we have collected a series of likelihood and impact figures produce self-assessments for personal performance appraisals; it
at consistent confidence levels for each significant activity. Now, is a tried and tested management technique. The only issue is that
how do we aggregate all of these numbers? people will not knowingly incriminate themselves.
Unfortunately, our bottom up assessments simply will not add That is not to say there is no value in a frank discussion on risk
up, nor do they lend themselves to easy modeling. Here is why: strengths and weaknesses with a business, but no firm wants its
even if they had been implemented with rigorous consistency and dirty laundry hung out in public. In fact quite the reverse — it
objectivity, the complexity of the many to many relationships and becomes a ‘make me look good’ exercise if it is going north.
dependencies between processes, risks and controls is too great. Declaring weaknesses will only be worthwhile if it evidences a need
Thousands of detailed risks and controls will diversify massively for more resources, or if it posits a ‘get out of jail free’ card, should
across the process universe, and the outputs will be highly a problem subsequently occur. Without independence, the risk
sensitive to our assumptions on loss distributions, dependencies assessment process can too easily be gamed.
and correlations. However, let us imagine we have a sophisticated What elements are we assessing? The original thinking was to
modeling tool and we can somehow cope with all of this. The focus on purely causal components of risk — people, systems,
outputs will still be very difficult to work through and explain to organization and external factors, often because there was too little
senior management who not only may not be statistically minded, objective data to assess these elements any other way. Most of the
but also incapable of feeding back the results in a meaningful way available data was process-related and could not take into account
“
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”
planned remediation. There is nothing more depressing for operational risk from which it is
Self-assessments are difficult to still struggling to shake free. Despite
keep fresh. When first introduced, for the risk department than being my comments in New York, It is not
senior business management might just a US problem — many major
be directly involved, but the
the reconciliation agent between European and Asian banks are either
following year it gets delegated until business self-assessments and internal US listed or encouraged by their
eventually a contractor, trainee or auditors or self-serving consulting
even intern is simply managing an audit’s risk assessment. firms to at least implement ‘Sox lite’.
update process, often within an Risk professionals may protest that
automated toolset. At this point the this is finance work, but that does
exercise is almost entirely without not fly if the CRO or Head of Risk
value; in fact it makes rather a mockery of what the assessment reports to the CFO. Besides, why duplicate the risk and internal
process should be trying to achieve. It is an abdication of risk audit assessment process if it can just be extended to work for
management responsibility, or at the very least, outsourcing to Sarbanes-Oxley as well? So operational risk headcounts have
much less qualified people to do it. spawned, but no one in the business is seeing the commercial
Furthermore, if a firm has an adequately resourced internal benefit of this new industry, because its focus has become too
audit department, self-assessment is often a substantial compliance driven.
duplication of what auditors are supposed to be doing We have talked about the flawed process of self-assessment,
independently. There is nothing more depressing for the risk but Sarbanes-Oxley is self-assessment on steroids. A colleague
department than being the reconciliation agent between business once shared an article early on when Sarbanes-Oxley was first
self-assessments and internal audit’s risk assessment. Given the being introduced, that it was at heart a don’t ask, don’t tell regime.
problems of gaming outlined above, in my experience the internal The example given was the one about the father who tells his
audit assessment is usually much more valuable. Self-assessment teenage daughter to behave when she goes to a party, and when
in my view is largely debunked. she appears in the morning looking bedraggled, not having slept
If all risk assessment is independent, it is then simply a matter much and quite hung over, he asks her if she behaved. ‘Yes Daddy’
of which elements the risk department performs and which are she replies, because she cannot give any other response. Like so
conducted by internal audit. Each firm must work out this boundary many outputs of self-assessment, this makes a mockery of risk
for itself, but intuitively, risk will own the risk framework and risk management, and sadly reflects a giant leap backwards in the
quantification including risk indicator metrics, and audit will assess development of the discipline.
the design and effectiveness internal controls and conduct some
measure of substantive testing. Start Again from the Top Down
I know many banks that have beaten their chests over their
Sarbanes-Oxley and the Industry of Compliance operational risk implementation because they hired armies of self-
I was once asked at a conference how my firm was integrating its assessment teams and gleaned little or no commercial benefit from
operational risk and Sarbanes-Oxley programs. I was the last to it. If anything, they got quite the opposite — they wasted a lot of
answer on a panel of four; the other participants were all senior risk business time and focus, lost in the undergrowth, unable to see the
officers at major US banks. Each had given a drawn-out response forest for the trees. None of them dares to call a halt though. What
but I simply said that my firm was not US listed and did not have to CRO wants to give the impression that he or she is not serious
comply with Sarbanes-Oxley. I immediately received a somewhat about all risks, however small? And if the CRO stopped, would
unexpected rapturous applause. there not be pressure to start again after a loss? But the calling card
Operational risk professionals and certainly the vendor market is poor, has put risk in the space of audit, and seriously damaged
had initially welcomed the budgets that came with the new the brand. Op risk has lost so much credibility over the industry of
Sarbanes-Oxley rules. The enthusiasm was short-lived. Up to that control self-assessment.
point, operational risk, although perhaps thinly resourced, had Instead, CROs and their op risk heads should have been
enjoyed a relative period of invention: regulators were happy to ‘let religiously focused on the top down perspective, collecting
a thousand flowers bloom’ in development of the discipline. The objective data to support their scenarios, and drilling into the detail
general impetus of the profession had been to collect data and give as and when needed. That way they would have been in a position
objectivity to the assessment process. Implementing operational to keep their departments lean, high quality, motivated and
risk management was about achieving a commercial benefit from commercially oriented. Unfortunately, few have had the courage or
understanding and managing risk exposures better — it was not shown the leadership to follow this path on a consistent basis. Too
about regulatory compliance for its own sake. many op risk functions became the collection points for disparate
Unfortunately, the new budgets that arrived with Sarbanes- risk assessment cottage industries rather than the strategic,
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R isk based supervision starts with the premise that not all firms are equally important to the economy and that a
supervisor can deliver most value through focusing its energies on the firms that are most significant and on the risks
that pose the greatest threat to financial stability and consumers. A risk based system should also provide a systematic
and structured means of assessing different types of risk, ensuring that idiosyncratic approaches to firm supervision are
avoided and potential risks are analyzed and mitigated using a common framework.
Over the past year, the Central Bank of Ireland has introduced more likely to help a supervisor identify and act upon the key
PRISM — a new risk-based framework and IT platform for risks at a regulated firm. We worked hard to defend the key
managing the supervision of the approximately 10,000 financial parts of that logic in the face of internal challenge throughout
firms for which we regulate. We have done this as part of our the design and build phases, while trying to accommodate
program to improve regulation in the wake of the 2008 financial others’ views. Having logical integrity was doubtless a pre-
crisis, and building upon lessons learned from specific domestic condition for subsequent successful operation of the
failings highlighted in various reports by Honohan, Nyberg and framework, and helped secure senior management team buy-
Regling and Watson. in but it did not, in and of itself, ensure acceptance from all
PRISM makes it easier for our supervisors to challenge the firms potential users. Front line staff, while they may have
they regulate, judge the risks they present and take action to appreciated the logical case we were making for change,
needed something more than that to encourage them to
mitigate those risks — securing meaningful change on behalf of
engage in the project.
consumers, citizens and the state. PRISM focuses attention on the
firms that have the highest potential impact on the economy,
■ Engagement — Rather than focusing on theory, we found that
making it materially less likely that they will fail in a disorderly
structured engagement with those who were required to
fashion. PRISM moves the Central Bank to a unified risk based
change their practices as a result of PRISM adoption yielded
system designed to make every euro we spend on supervision go
significant benefits:
as far as possible, a system which encourages supervisors to focus
on the issues which really count. • In the first instance, we recruited representatives from all the
For supervisors, adapting to the new approaches to supervision supervisory divisions to participate in the graphical user
embedded within PRISM has involved a lot of flexibility and a lot of interface (GUI) design process. This meant that we had the
change. As financial institutions adapt to the new regulatory and look and feel of all the system’s modules structured by
political realities, many are likely to be in need of improvements to practical users rather than professional programmers. It also
their practices and will be required to undertake significant change meant that we had, de facto, a cadre of high caliber change
agents within each division.
programs in order to meet the new higher expectations of the
Central Bank and the wider public. In the article I highlight some of • The benefits of visual stimuli to give future users an
the lessons we learned and some of the things we did which proved understanding of the positive aspects of change cannot be
successful in our work to renew supervision at the Central Bank: overestimated. PRISM is both a framework for supervision
and a bespoke IT system. We went to some trouble to show
■ Logic — Change is often used as a mantra — almost an end in an early incomplete system to future users and managers to
itself — by managers who fail to explain what it means and why allow them to see what it would look like. This made what we
it will make life better for the employees who are to experience were talking about much more real and, as future adopters
the change. Conscious of this, prior to designing and building saw that it was considerably more clever than an Excel
PRISM we studied regulatory frameworks, such as those used workbook, they began to believe that change might be
by Australia and Canada, to ensure that what we constructed positive, time-saving and empowering.
was both fit-for-purpose and reflected current regulatory best
• When training supervisors, we engaged with senior
practice. We then developed a theoretical framework drawing
supervisors and involved them in the delivery of parts of the
on that best practice, with input from senior staff in our own
training. In this way, we enabled them to demonstrate line
organization. Critical to the intellectual robustness of the
management buy-in to PRISM. We also invested heavily in
framework we were trying to construct was to obtain top-level
credible senior trainers with an in-depth knowledge of
buy-in. Coherent logic underlying the entire system has been
supervision who easily gained the respect of those they were
vital in ensuring that it is intellectually robust and therefore
training.
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• Having formally launched PRISM we held follow up training some of the ideas directly contradicted other ideas. We found
sessions that allowed us to support supervisors doing real using formal forums to manage the feedback essential to
work on the system for the first time. This helped bridge the ensure that the top tier of management in the Central Bank
gap between theoretical exercises and actually making the discussed the good aspects and weaker aspects of ideas, with
system work for supervisors for the first time. They went decisions clearly minuted. At such forums, the risk division had
away from these training sessions having started to populate to learn to bend with the wind and stretch to adapt the system
the system with risk analysis on their firms. to meet emerging client needs, while preserving key aspects of
its logic. The unswerving support of the Deputy Governor,
• Following the first release of the system we had structured
Financial Regulation was vital and I would observe that any
feedback meetings with key user groups to understand how
head of risk who agrees to implement a major framework
they were finding the system and what practical capabilities
change without the active support of his or her CEO, is taking
they were finding it lacked. By responding quickly once we
a “courageous step” as Sir Humphrey Appleby would have
had listened to feedback, we were able to incorporate several
put it.
of their suggestions for improvement into the second phase
of the build, delivering the improvements swiftly. Such
We certainly did not get everything right while designing and
responsiveness on our part helped to build trust.
delivering PRISM at the Central Bank. It was fascinating to observe
the necessity of and yet the limits of a good theory as a change
■ Support — Without appropriate support, we would have found
it impossible to deliver a high quality system to very tight agent and the vital importance of the many types of participatory
deadlines. We spent a lot of time and energy procuring high engagement we deployed with those who would be called upon to
quality external support. Our principal IT build consultants make the change a reality in our “front office." The importance of
committed themselves to giving us the same team for all four fully committed teams who understood and were prepared to
phases (one design stage and three stages of build) with the strive for the strategic benefits of the change was brought home to
same people co-located in our office throughout the project. me again and again as deadlines approached and people — risk,
This gave us a great deal of flexibility in responding to feedback supervisors and in-house IT — in a public service environment —
and achieving fast turnaround times. Further to that, we used worked very long hours to deliver their pieces of the jigsaw puzzle.
external consultants to act as a thought partner on aspects of Having consultants who were flexible enough to run with you
our regulatory thinking – providing impartial advice on the logic rather than reading to you out of their manuals on how to run was
and practicality of our design. Switching to internal support, I also important for a bespoke framework. Our software developers
was given a headcount rather than a team when I took up my could be pushed to achieve, but were also quite adept at indicating
post and was asked to design the new system. This was hard the limits to the possible rather than overpromising and under
work at first but it gave my deputy and me a lot of flexibility to delivering.
recruit staff from a broad range of backgrounds — people who In summary, logic, engagement, support and understanding
signed up because they wanted to make a difference and liked feedback are all vital when designing and implementing a major
the sound of the change project that PRISM had become. organizational change, as are, of course, a good appreciation of the
While this had occasional downsides in terms of my teams not art as well as the limits of the possible.
always having experienced line supervision, it ensured that
there was a lot of constructive challenge from those coming The views in this article are the author’s own and do not necessarily
into the risk division without supervisory experience. This represent the official views of the Central Bank of Ireland.
forced us to improve our standards of communication. I ended
up with a team of enthusiastic volunteers — no one was there
because they had been told they had to be. It also meant that
there were few people who were unduly attached to previous
approaches — an issue for some change projects. We were ABOUT THE AUTHOR
also blessed with a supportive COO and an IT department that
was intellectually interested in what we were doing and William Mason heads the Central Bank of
prepared to experiment with new approaches and put itself out Ireland's Risk Division. He led the design
and build of its new risk-based supervision
to meet our tight deadlines.
system - PRISM. Prior to joining the
Central Bank, he supervised a range of
■ Feedback — Managing feedback was very important
credit institutions, insurers and invest-
throughout the process. Lots of people had constructive ideas
ment firms at the UK Financial Services
as to how the new system should work. The issues we faced
Authority. He also authored regulatory improvement propos-
were, first, that not all the ideas could be practically als at the UK’s Better Regulation Task Force, including
accomplished in a design phase measured in weeks and a build 'Regulation — Less is More — a report to the Prime Minister’.
phase measured in a few short months and, secondly, that
Abstract
When modelling credit spreads, there is some controversy in the market as to whether they are mean-reverting
or not. This is particularly important in the context of counterparty risk, at least for risk management and capi-
tal calculations, as those models need to backtest correctly and, hence, they need to follow the “real” measure,
as opposed to the “risk-neutral” one. This paper shows evidence that the credit spreads of individual corporate
names, by themselves, are not mean-reverting. Our results also suggest that a mean-reversion feature should be
implemented in the context of joint spread-default modelling, but not in a spread-only model.
Arguably, building a credit model for counterparty risk has some January 2005 to January 2012 for 23 corporate names covering a
important challenges. There are a number of well-developed and range of credit qualities. Figure 1 shows those time series.
sophisticated models for this asset class in the literature, but they
have mostly been developed in the context of derivatives pricing.
A pricing model is good when it provides (i) no arbitrage gaps,
(ii) good greeks that enable hedging strategies and, obviously,
(iii) reasonable prices. In the world of risk management and capital
calculation, a model is good when it backtests properly. That is, risk
management needs the distributions arising from the models to be
as close as possible to the actual distributions seen in the market.
For that reason, while derivatives pricing models typically use the
“risk-neutral” measure, risk management and capital calculation
models tend to use the “real" measure.
In particular, in the credit asset class, one of the stylised
facts that credit spread models often mimic is mean-reversion.
However, there is some controversy as to whether the credit
spreads are mean-reverting or not. In early studies of credit
spreads, they were considered mean-reverting, but this was
not the case in later studies.[1, 2].
This paper tackles that question: are credit spreads mean- Figure 1: Times series of 5-year credit spreads for a number of
reverting? names, from January 2005 to January 2012. Source: Credit Suisse.
d xt = θ o u ( μ o u – x t )d t+ σ o u dWt
2. A GBM Compatibility Test.
1. Error bars indicate the 99% confidence interval assuming a normal distribution with the empirical standard deviation.
2. See VIX time series in Appendix.
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The reader can see in those graphs how the zero value is
included within the error bars in most cases.
Let’s say that the null hypothesis is that “the mean
reversion parameter speed θ is zero for corporate credit
spreads”. The data shown in Figures 2 and 3 illustrates
that this null hypothesis should not be rejected3.
3. Strictly speaking, we should expect that in a few out of the 23 measurements, the zero value for θ should be outside of the 99% confidence interval even when
the null hypothesis is not rejected. However, the authors are not being specific about how many is “a few" as there is uncertainty regarding the actual distribution of
the error. They have assumed that the latter is normally distributed, but that might not be the case. In any case, in spite of this lack of strict precision, the authors
think that it will be unreasonable to reject the null hypothesis given the data obtained.
4. With a volatility of 100%, which is a typical volatility observed in the time series of the credit spread time series.
References
[1] H. Bierens, J. zhi Huang, and W. Kong, An econometric model of credit
spreads with rebalancing, arch and jump effects. Working Paper, 2003.
5. Again, strictly speaking, this exercise should be done per measured θ . Ideally, the following should be done: (i) measure θ for each name and model (as it
has been done) as well as the volatility σ , (ii) generate 10,000 paths for each one of the 23 time series and model (OU and BK) with θ = 0 and with a volatility
of σ and (iii) calculate a p-value of each θ from which the validity of each mean-reversion speed can be assessed. Instead, the authors have taken an average
volatility of 100%, generated 10,000 GBM paths (as the credit spreads cannot be negative) and use these statistics to validate all values of θ . However, the con-
clusion using this shortcut are so clear that the authors think that the strict analysis explained in this footnote is not strictly necessary.
6. Null hypothesis: “the mean reversion parameter speed θ is zero for corporate credit spreads”.
Ignacio Ruiz, founding director of iRuiz Piero Del Boca is a quantitative risk analyst
Consulting ltd, London, established himself at Credit Suisse. Before that he was a quan-
as a contractor and independent consultant titative fixed income analyst at the asset
in Quantitative Risk and CVA in 2010. management division of Eurizon Capital at
Before that he was the head quant for Milan. He holds an MSc in theoretical
counterparty credit risk, exposure meas- physics from Università degli Studi di
urement, at Credit Suisse and the head of Milano, Italy, and an MSc in financial math-
equity risk methodology at BNP Paribas. He ematics from Warwick Business School,
holds a Ph.D. degree in nano-physics from Cambridge University, UK. [email protected]. Piero Del Boc is not com-
UK, and an advanced degree in theoretical physics from mercially related to iRuiz Consulting Ltd.
Complutense University, Spain. www.iruizconsulting.com
[email protected]
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VISIONS OF RISK SPONSOR ARTICLE
T he Financial Services Authority defines reverse stress tests as “tests that require a firm to assess scenarios and circum-
stances that would render its business model unviable, thereby identifying potential business vulnerabilities. Reverse stress-
testing starts from an outcome of business failure and identifies circumstances where this might occur. This is different to gen-
eral stress and scenario testing which tests for outcomes arising from changes in circumstances.”
At its core, reverse stress testing (RST) proposes to “invert” the stress testing process f : X → Y will help us ensure that (at least
~
X ={ x~ ∈ X ⊆ R̋ ˄ ~ x ∈ f -1 (y 0)} . Under some “regularity”
quantitative way, multiplicity emerges as a challenge. The same understand the shape of the solution-set
~
conditions for f , the set X will locally map X → Y (stress
outcome (for example, high expected losses) could materialize
The top five UK factors explain over 90% of the variability of the replicated by these five factors. But what do these factors
whole sample, with factors 1 and 2 explaining 50% and 20%, represent? Figures I to VI show the correlation of the factors to
respectively. This is encouraging news from a RST angle; almost all specific economic indicators.
of the information embedded in the UK economic cycle can be
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assumption for the outcome, say Y 1+1 , and find consistent values
macro variables and factors, the modeler responsible for RST has a
s
Suppose now that the RST mandate is to start with an
2.2 — Handling Type-2 Multiplicity: The Case of Linear Models working on the RST process. With an equal number of targets and
outcome Y 1+1 .
economic and other risk drivers. Properties of the coefficient
matrices of these linear systems will determine whether the
process can be “inverted”. The simplest 1-dimensional linear model With non-linear transformations of the original risk variables
will require a non-zero estimated coefficient. When dealing with that are strictly monotone (as it is the case for logarithmic and
higher order systems, the non-zero condition translates to the logistic mappings), the modeler is able to avoid type-2 multiplicity
determinant of a specific matrix. and the RST exercise can be carried forward.
Dr. Juan M. Licari is a Senior Director at Dr. Jose Suarez-Lledo is an associate direc-
Moody’s Analytics and the head of the tor at Moody’s Analytics based in London.
Credit Analytics team for Europe, the As part of the Credit Analytics team he
Middle East, and Africa. Dr. Licari’s team designs retail and corporate credit models
provides consulting support to major as well as macro-econometric models for
industry players, builds econometric tools key economic and financial variables.
to model credit phenomena, and imple- Before joining Moody’s Analytics, Jose held
ments several stress-testing platforms to quantify portfolio risk a research position at the Universidad Autonoma de Barcelona,
exposure. His team is an industry leader in developing and imple- where he developed models for illiquid financial markets and the
menting credit solutions that explicitly connect credit data to the dynamics of asset prices and credit. Jose holds a Ph.D. and an
underlying economic cycle, allowing portfolio managers to plan MA in Economics from the University of Pennsylvania.
for alternative macroeconomic scenarios.
Juan is actively involved in communicating the team’s
research and methodologies to the market. He often speaks at
credit events and economic conferences worldwide. Dr. Licari
holds a Ph.D. and an MA in economics from the University of
Pennsylvania and graduated summa cum laude from the
National University of Cordoba in Argentina.
ABOUT THE SPONSOR Moody’s Analytics helps capital markets and risk management professionals
worldwide respond to an evolving marketplace with confidence. The company
offers unique tools and best practices for measuring and managing risk through
expertise and experience in credit analysis, economic research and financial risk
management. By providing leading-edge software, advisory services, and research,
including the proprietary analysis of Moody’s Investors Service, Moody’s Analytics
integrates and customizes its offerings to address specific business challenges.
For more information please visit: www.moodysanalytics.com/RSTmacro
18 INTELLIGENT RISK M O O DY A N A LY T I C S S P O N S O R A R T I C L E
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CHAPTER REPORT
T he Philippines Department of Tourism recently reintroduced the Filipino FUN through its new tagline — IT’S MORE
FUN IN THE PHILIPPINES. This concept is captured by not only the nation’s beautiful scenery, exotic attractions
and daily life in general, but also by the lively mood, bright smiles and limitless humor of its citizens. Filipino FUN gives
the whole world a peek into the resilience and positivity of the Filipino spirit, which remains undaunted by tragedy, polit-
ical unrest and day-to-day challenges.
PRMIA PHILIPPINES O C TO B E R 2 0 1 2 19
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WHAT’S ON THE WEB EXPERT GUIDES TO THE BEST LINKS
H aving a robust risk management function and governance system is seen as crucial after the global financial crisis.
Such factors as chief risk officer qualifications and status, executive compensation and board composition have
increasingly become a focus of regulatory bodies and researchers. While our research in the field of corporate gover-
nance regulation has drawn from many sources, we have found several websites that have been particularly important.
I have listed them below in hopes that readers of Intelligent Risk will find them useful as well.
THE NATIONAL BUREAU OF ECONOMIC RESEARCH – THE BASEL COMMITTEE ON BANKING SUPERVISION
RISKS OF FINANCIAL INSTITUTIONS http://www.bis.org/bcbs
http://www.nber.org/workinggroups/fr/fr.html
Rating: ★★★★
Rating: ★★★★★
This website is a great starting point for exploration of the topic of
The NBER is a private, nonprofit research organization. One goal of regulations and governance. A good example is “Principles for
the NBER's Working Group on the Risks of Financial Institutions is enhancing corporate governance” which provides the recom-
to improve the understanding of risks in financial markets and to mendations of the Basel Committee at
investigate how regulations affect these risks. The working group’s http://www.bis.org/publ/bcbs176.pdf. This 2010 document
website provides several research papers. Particularly interesting is summarizes the lessons learned from the financial crisis of
“Stronger Risk Controls, Lower Risk: Evidence from U.S. Bank 2007-08.
Holding Companies,” by Andrew Ellul and Vijay Yerramilli, which Other interesting papers from the Basel Committee include
analyzes the influence of strong and independent risk management “External audit quality and banking supervision” which describes
functions on enterprise-wide risk: the roles of supervisors and external auditors:
http://www.nber.org/papers/w16178 http://www.bis.org/publ/bcbs146.pdf and
Also see the research paper “Yesterday’s Heroes: “Core principles of effective banking supervision”
Compensation and Creative Risk-Taking” by Ing-Haw Cheng, http://www.bis.org/publ/bcbs213.pdf
Harrison Hong and Jose A. Scheinkman, which explores the
relationship between compensation and risk-taking among finance
firms: http://www.nber.org/papers/w16176 THE HARVARD LAW SCHOOL FORUM ON CORPORATE
GOVERNANCE AND FINANCIAL REGULATION
http://blogs.law.harvard.edu/corpgov/
RESEARCH AT THE WORLD BANK
Rating: ★★★★
http://bit.ly/53q9td
This Forum provides updates on working papers, seminars, speak-
Rating: ★★★★★
ers, and other activities in the field of corporate governance and
Three researches at the World Bank, James R. Barth, Gerard Caprio, financial regulation. One example, “Toward Effective Governance
Jr. and Ross Levine, examine a cross-country survey on bank of Financial Institutions,” features Lord Adair Turner, Chairman of
regulation in the years 2000, 2003 and 2007. Since regulatory the United Kingdom Financial Services Authority, discussing the
certainly plays such an important role in risk management, the features of an effective governance structure and offering his
results of these surveys are fascinating. recommendations: http://hvrd.me/Jn8sDk
In addition to providing raw survey data, the researchers have
published several papers analyzing the influence of regulation on
bank performance and how this has changed over the years
including: “Bank Regulation and Supervision: What works best”
http://bit.ly/RfmXvv and “Bank Regulations Are Changing: For
Better or Worse” http://siteresources.worldbank.org/INTRES/
Resources/ForBetter_or_Worse_final.pdf
20 INTELLIGENT RISK W H AT ’ S O N T H E W E B
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The website of the Institute of International Finance (IIF) offers The non-profit association ECGI provides research and advice on
insights on its approach toward the development of best practices the formulation of corporate governance policy. The ECGI publishes
and standards for the financial industry. The subcategory a Research Newsletter that gives an overview of the hot topics in
“Regulatory Affairs” discusses current developments in regulation corporate governance as well as the current research:
and their impact on banks. Many useful gems can be found here, http://www.ecgi.org/research/index.php
including the paper “Implementing Robust Risk Appetite
Frameworks to Strengthen Financial Institutions,” which gives Two series, the Working Paper Series in Finance and the Working
excellent practical guidance for those seeking to determine a risk Paper Series in Law include downloadable research papers from
appetite framework: several academics. One paper of interest is entitled “Why Did
http://www.iif.com/regulatory/article+968.php Some Banks Perform Better during the Credit Crisis? A Cross-
Country Study of the Impact of Governance and Regulation,” and
“Compensation Reform in Wholesale Banking 2011” was produced was written by Andrea Beltratti and René Stulz:
jointly by IIF and Oliver Wyman and provides the third annual http://www.ecgi.org/wp/wp_id.php?id=386
survey of its type:
http://www.iif.com/regulatory/article+1026.php The paper investigates whether bank performance is related to
bank-level governance, country-level governance, country-level
Another interesting publication is a survey that the IIF conducted in regulation, and bank balance sheet and profitability characteristics.
cooperation with Ernst and Young, “Progress in Financial Risk
Management” http://bit.ly/MgdxMd
THE SENIOR SUPERVISORS GROUP (SSG)
Additionally, the IIF publishes the Global Regulatory Update, which
Rating: ★★★
IIF members may access free:
http://www.iif.com/regulatory/gru/ The SSG is made up of senior representatives of several superviso-
ry authorities. Although the SSG does not have a specific website,
several regulatory agencies publish its works. One interesting arti-
cle, “Observations on Risk Management Practices during the
Recent Market Turbulence,” can be found at: http://bit.ly/lEJlm
Anna Lingel is a student at the University of Augsburg/Technische Universität Münich, currently working toward a
Master of Science degree in Finance and Information Management. As part of her degree, Anna is working on a
research project in risk management, with Elizabeth Sheedy, Associate Professor, Macquarie University Applied
Finance Centre in Sydney. For more information, please contact Anna at [email protected].
R I S K M A N AG E M E N T A N D G OV E R N A N C E O F F I N A N C I A L I N S T I T U T I O N S O C TO B E R 2 0 1 2 21
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LEARNING OPPORTUNITIES
S ince the global recession began in 2008 the demand for risk management training has dramatically increased
at all levels. In response, our training is evolving in line with member needs. PRMIA recognizes the diversity in
this renewed demand and has responded by providing a library of risk education tools, delivered in brief via online
and web-based training solutions, as well as through live classroom and customized in-house training. All plat-
forms are created and delivered by leading industry experts.
ONLINE SERVICES
Available anytime, anywhere in the
world with an internet connection.
WEBINARS
Most of our webinars are free to Sustaining Members. They are
the perfect option for professionals that desire flexibility, are
cost-conscious, and do not want to sacrifice quality. PRMIA
webinars bring the international thought leaders in risk
management live to your screen. Ask them a question and CLASSROOM TRAINING
participate in questions to the audience. Or, being recorded, you
Intensive and Comprehensive
may prefer a time and location that is more convenient than the
broadcast slot. Already a global market leader in risk
CUSTOMIZED COURSES
management webinars, we are expanding our schedule even
Customized courses are held in-house or at specialized training
further during 2012. Watch your e-mail and check the website
venues. One-to-one consultation with our specialist training
for updated schedules on http://bit.ly/PRMIAWebinars
professionals ensures that the learning experience is tailor-
made to your requirements. Our goal is to provide training that
PROFESSIONAL DEVELOPMENT
is flexible and sensitive to delegates’ needs, knowledge and
PRMIA offers over 700 online professional development
background. Enquiries: [email protected]
courses, all of which can be customized to your personal or
corporate needs. Delivered individually or as a corporate
OPEN ENROLLMENT COURSES
package, online training is extremely cost-effective, with most
Open enrollment courses meet the needs of members who
individual courses priced at only US $25. Special pricing is
prefer to interact and network with other risk professionals
available for corporate licensing of any online course or course
while receiving a more rigorous training experience. All PRMIA
combination. See http://bit.ly/PRMIAOnlineTraining
courses are taught by risk management industry practitioners and
university faculty, offering a unique blend of teaching. We have
EXAMINATION PREPARATION
several classroom courses scheduled over the next few months
PRMIA offers access to multiple resources to assist candidates
and our schedule will continue to develop throughout 2012 as
in the exam preparation process. These resources include
we receive feedback and guidance from members and leaders.
printed publications, online training, webinars, classroom
See next page for current classes or click here for a list of
training and DVDs. A full list of online exam preparation material
upcoming courses.
is on http://bit.ly/PRMIAExamPrep
“This short course on risk management (Complete Course in Risk Management) crams more into its 20-
week span than many other certificate or even degree level courses. The professors are excellent and the
material ensures a solid foundation in the subject. I would unhesitatingly recommend this course.”
Jay Namputhiripad, Director, Risk Management, Federal Home Loan Banks Office of Finance
28 W H AT ’ S O N T H E W E B
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OPEN ENROLLMENT COURSES
K ent Business School (KBS) at the University of Kent in Canterbury, UK, launched in 1988, has built a strong portfolio
of undergraduate, postgraduate and PhD degree programs, as well as non-degree ‘part time’ executive education
for both individuals and companies. These cover a wide range of activities, including risk analysis of financial products,
derivatives pricing, econometrics of financial markets and quantitative finance for capital markets. The 25 years of pro-
fessional and academic excellence have shaped KBS into a true intellectual hub for business students,
academics, local government and the private industry. As a result, KBS is now among the top 25 business schools in the
United Kingdom and enjoys an established reputation for research collaborations with the business industry.
The one-year Master’s in Financial Markets, currently seeking published in various top finance journals including Journal of
accreditation from PRMIA, has been designed to cover advanced Banking and Finance; Journal of Empirical Finance; Journal of
and core topics required by finance industry employers worldwide, Futures Markets; Quantitative Finance; International Journal of
including risk management, derivative products, corporate finance, Theoretical and Applied Finance; Journal of Portfolio Management;
market and credit risk analysis, econometric modeling of financial European Journal of Finance; Journal of Investing; Review of
time-series, financial engineering and fixed income. In addition to Quantitative Finance and Accounting; Journal of International
the standard lecture and workshop/ seminar training, students Financial Markets; Institutions and Money; Applied Financial
enrolled in this Master’s program dedicate the summer term to a Economics and European Financial Management.
15,000 word dissertation on a financial topic of their choice, under The status of PRMIA academic partner — which reflects the
personalized guidance from KBS academia, thus ensuring that core intrinsic value of our staff and programs in finance — places KBS
and advanced knowledge is grounded and students are fully alongside top providers of financial education worldwide.
prepared for the next stage in their careers. KBS also offers an MSc Furthermore, the accreditation by PRMIA, which we currently seek
in Financial Services in Banking. Core modules for this program for our MSc in Financial Markets, represents another notable
include financial regulation, financial institutions, commercial and milestone in the integration of this program in the international
investment banking and corporate finance. KBS students have gone elite of Master’s programs in Finance. In addition, the finance group
on into careers in the financial industry as derivatives traders, at KBS is currently exploring academic links in postgraduate
corporate finance and risk management analysts, start-up finance finance, taught and researched with reputable institutions from
specialists, business financial managers, and research associates, Brazil, Hong Kong and Switzerland.
to mention a few of the opportunities opened after graduating with Recently, we established relationships with financial services
a KBS MSc. For more information on our programs, visit: companies interested in specific projects and joint events. A
http://www.kent.ac.uk/kbs/programmes/masters/specialist notable example is the UK accountancy firm Crowe Clark Whitehill
finance.html LLP — part of Crowe Horwath International, the ninth-largest
Members of the academic staff in finance at Kent Business association of professional audit and advisory services firms in the
School conduct research in diverse areas such as credit and market world — where some of our best students will enhance their
risk modeling, hedging, financial markets integration, theoretical practical knowledge. For more information please visit our website
financial econometrics, and model risk. Their work has been at: http://www.kent.ac.uk/kbs
24 INTELLIGENT RISK AC A D E M I C PA R T N E R P R O F I L E
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PRMIA LEADERSHIP BOARD OF DIRECTORS
FARUK PATEL
Manager, Investment Risk, Alberta Investment BARRY SCHACHTER CHAE SING WONG
Management Corporation (AIMCo) Director, PRMIA Senior Vice President/Head of Asia
Business Risk Management, Marsh
PRMIA Involvement PRMIA Involvement
■ Co-Regional Director, Edmonton ■ Education Committee PRMIA Involvement
■ Former Chair, Regional Director Standards ■ Co-Chair, Publications Committee ■Former Co-Regional Director,
& Support Committee Term Expiration: 2013 Beijing Chapter
■ Former Co-Regional Director, Montreal
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