Effective Risk Oversight in a Changing World: Principles and Guidance for Board Risk Committees and Risk Functions in the UK Financial Services Sector (Response to the Risk Coalition Consultation)

Abstract

In June 2019 the Risk Coalition published a consultation document of their principles and guidance for board risk committees and risk functions in the UK financial services sector. This draft document entitled "Effective Risk Oversight in a Changing World" was open for public comment until 20th September 2019 and the Risk Coalition plans to issue the final version of the guidance in December 2019. The Risk Coalition aspires to improve risk governance and risk management in the UK financial services sector by providing clear and authoritative principle-based guidance. This guidance sets out to (a) develop a common understanding of the purpose and remit of board risk committees and risk functions, (b) raise expectations and promote good practice of risk oversight in UK financial services, and (c) provide a benchmark against which board risk committees and risk functions can be objectively assessed. This submission provides comments to address the risk oversight issue from two distinct perspectives: 1. General Observations This section addresses the following issues in the context of risk oversight: (a) the requirement for holistic risk oversight, and (b) delivering a holistic risk oversight framework 2. Response to Specific Questions This section provides feedback in relation to the specific consultation questions outlined by the Risk Coalition in the consultation document. Post-mortem investigations into the causes of ongoing corporate fiascos and financial scandals continue to identify both failures in corporate governance and poor risk management as major contributors. I welcome the initiative to provide clear and authoritative principles-based guidance in the area of risk governance, risk oversight, and risk management. Improved risk oversight can have a very important role to play in helping to better safeguard stakeholder interests going forward. The comments included in this submission are therefore intended to be a constructive attempt to contribute to the further improvement of the consultation document prior to being finalised.