[Warning: Long-read. Opiniated, and structurally your recommendations may be are needed, too]
About all of the banking industry, and other financials in their wake, have had to deal with loads of regulatory requirements. Justified, some say, for ‘they’ cause(d) so much misery beyond mere most temporary loss of bonuses that the ‘un’ should be (have been long before) detached from bridled. So, Basel II and -III regulations swooped in requiring much more explicit and detailed handling of financial business than ever before. The move from laissez-faire to regulation, to regulation with sanction schemes, to sanctions (possibly interpreted as ‘token’…), was extended with provability and then complete proof-demonstration as minimum requirement.
This all, however, has created a large, and in general even I would say quite overpaid [disclaimer: am profiting too] industry of consultants, quants, ‘risk managers’, reviewers, assessors, auditors, and scores of Toms, Dicks1 and Harries of the GRC kind. That are all very likeable nice lads and lassies, but maybe not quite worth their salt, certainly not their bonuses, or even be sure to be worth much lending one’s ear to.
Since March, suddenly, there’s news. The Basel Committee on Banking Supervision has released a consultative paper on ideas for (much-needed, many know) simplification of the operational risk management part of regulations. For Basel-IV forthcoming.
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