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    Computational Management Symposium 2004

    Long Term Policy Making for Operational Risk management

    in the Basel II framework

    University of NeuchatelRoom ALG Session 16

    Duc PHAM-HI,

    Head of IT Dept.,prof. Computational Finance,

    E.C.E engineering school, Paris, France

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    Focus is on Risk management in Banks

    Definitions (New Basel Accord)

    "risk of loss from failed or inadequate process, systems or people,

    resulting from internal or external events"

    Basel II means profound changes

    quantification of op risks for mandatory Capital reserves involvement of top management, held accountable

    very large compliance projects

    Operational Risk in banks

    7 event categories

    quantitative approach

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    Operational risk: Advanced Model Approach

    Loss distribution approach

    hope for lower Capital requirements

    risk control performances watched by Rating agencies

    Probability

    Loss occurences

    individual Loss

    amount

    Monte Carlo

    Simulation

    etc.

    Probability

    Total loss

    Mean Threshold

    Probability

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    Basel II, computation-wise

    Basel II for the Top banks : Advanced Model Approach

    Pillar 1: capital at risk calculation

    use of all 4 inputs mandatory, but internal data scarce

    allocation between part and whole?

    source of risk is absent from model

    Pillar 2: control and supervision governance and management role are not modelised

    consistency and rationality: no objective way to judge

    General:

    procyclicity

    look-back

    etc

    Conclusion : crying lack for a theory of dynamic risk control to build a

    rational framework

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    2 kinds of risks

    "Business losses" are frequent, and small, and :

    rather regular

    both positive and negative

    "Catastrophic losses" are rare and very large and

    unpredictable

    only negative ("no free lunch" effect)

    Levy process for modeling risk state

    Ordinary

    business losses

    Negligible losses

    Extraordinary

    catastrophic

    losses

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    Bank activity variables for modeling business

    Small and frequent losses

    Rare but very large losses

    after application of Ito's formula, where :

    is the compensated Poisson random measure,

    (dz) is the Lvy measure, with condition

    All operational losses

    Revenue income process

    Wealth is resultant of losses and gains

    ttBXX ex

    p0,11

    tLXX exp0,22

    21 dXdXdX

    dtdR

    tdBXdX 11

    **

    R 122 ),(

    ~)1()()1(

    R

    z

    z

    z dzdtNedtdzzebXdX

    )(),(),(~

    dzdtdzdtNdzdtN

    1),(1

    z

    z dzdte

    dXdRdW

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    Parameters for modeling Management

    Key Risk Indicators and Scorecards on Business Environment :

    indicates level of danger/volatility

    Scorecards on Internal Control

    How effective does Management transform budgets into Loss

    reduction

    Approximation

    Assmussen & Rosinski

    Cumulated large losses as finite number of jumps, in practical

    )(

    1

    tN

    jt xX

    t

    t

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    Reducing small losses

    through better process management

    where tis the loss reduction factor whose cost is expense

    (more fraud detection, personnel, etc.)

    Reducing impact of catastrophic events through insurance, or

    recovery plans, at cost

    where losses xj may be capped or reduced

    Impacts on system

    Risk state description: effects of management / environment

    Wealth WWealth

    W+dWTransition Probability

    Control

    variables ,

    Environt var.

    )()( ttF

    )(

    0

    )()(tN

    jt xKLG

    amountfixedHwherexHxK jj )(),(inf)(

    1)(0).()( HwherexHxK jj

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    Introducing rationality and control

    Wealth evolution is :

    State of wealth at time :

    Economic value depending on policy

    where is the given of a pair ( (t) , (t)) .

    Objective is to maximise:

    )(

    1

    1 )()()()(tN

    j

    jtt xKdBXdtRdW

    0

    ),,),(,,( ttttdWW

    dttWUrtJ0

    )()exp(

    dttWUrtEV0

    )()exp(max

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    Other related problems :

    Refer to Cramer-Lundberg : Ruin theory

    Goal to stay afloat becomes constraint

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    How to solve : 3 choices of methods

    Pure HJB, G-HJB :

    Galerkin + Viscosity

    consistent with events classification

    Neural / Learning

    Adaptive: Reinforcement LearningNeural, supervised

    QMC or MCMC exploratory

    Has to back test and stress test anyway Scenario exploration thru parameters : Markov chaining events

    instead of Experts panel imagination.

    Classic dilemma : explore or exploitation : genetic programming

    (splice & dice)

    kkrJ

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    Using Hamilton Jacobi Bellman to model risk ?

    Introducing processes

    Optimal control gives the big picture

    Modeling processes

    Process decomposition

    Equation for risk genesis

    Introducing Value

    Optimal control equations

    Solving for strategies

    Solving for price of risk

    Feature based reasoning

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    Drawing help from Techniques of process modeling

    Classification as Top down or Bottom up

    Or, as either Process / Factor :

    process analysis

    causal networks

    connectivity matrix

    factors identification

    risk indicators - and predictive models CAPM like and volatility models

    actuarial techniques

    empirical loss distribution

    distributional form parametricized by historical data extreme value theory

    Hamilton Jacobi Bellman is related to process

    but transition matrix in Markovian case can be related to Bayesian

    networks.

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    Banking processes and losses separation

    Need for a separate process model and a Losses model...

    Risks identification is different from risk evaluation

    one is cost, other is production

    capital at risk evaluation is not (always) risk evaluation

    Risk evaluation cannot be done properly without risk reduction

    which cannot be treated if generation mechanism not seen

    parameters for risk source easier to catch at op level

    De facto schizoid treatment separating identification

    that combines back together

    at time dimension

    cost reduction, management from Y to Y+1

    at investment cost dimension

    allocate CaR according to marginal efficiency of capital, not at

    highest ex post costs therefore justify event type cats as axis

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    Modeling hypotheses and issues

    Standard approach (not AMA) and line of business

    Basel II is profit center orientated, not back office... but operational risk stems from back office

    modeling correlation errors if share back office processes

    markovian hypothesis

    homogeneity issue on local risk-adjusted returns on capital across

    different business lines

    Elements for the process model

    profit generation rate

    estimates of

    risk level factor stochastic variable

    is a LDA type : Extreme value theory to help here.

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    Long history of solving HJB

    Known cases Linear Quadratic

    in Merton's problem and Black Scholes context

    New : with Levy processes, but with HARA and CARA

    utility function : explicit solutions

    But still, classic obstacles

    Unknown P(x,y) --> POMDP in Markovian case

    Curse of dimensionality

    Too large sets {y} for each x Too large sets { } for each x

    Too strong nonlinearities

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    Learning : quick sampling of state space wrt. rewards

    Neural techniques on features

    Mixing SDE with NN-based volatilities

    To use Q-learning, philosophy is Action-Reward : use of at :

    at= (xt) ,

    Then

    Taking null terminal value, the value function is the total of what can be

    expected in the future (here discount is not present).

    Introducing a discount rate and taking the expected value :

    ),(),( axrEaxR

    0)),(,()),(,(

    t tt dttxxrtxxV

    0

    0))(,()(t

    tt

    t xxxxrExV

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    Rationality of the risk center is to seek maximum of value, starting from state t

    x0, to "learn" policy maximising V over set A of admissible actionssatisfying

    where V (x) is the the consequence of following policy from initial situation x

    Value for a given strategy is sum of immediate reward and discounted flow of

    possible future rewards, depending on the transition :

    Solving for optimal policy requires dealing with nonlinear equation

    Solving for strategies or for value of risk ?

    0

    * ))(,())(,(minarg)(t

    tt

    t xxrExxRx

    )(min)( 00*

    xVxVA

    0

    ))(,())(,()(t

    tt

    t xxrExxRxV

    y

    tyxtt yVPxRxV )(..),()( ,11

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    Solving for strategies is non-linear, we turn to solving for value (G is terminal

    value)

    by reasoning in terms of discrete time. Alternately, in terms of discrete states y, as

    possible outcomes of state x, and introducing action at:

    We iterate on V since the problem is linear.

    let tbe the proxy for V at time t ; we iterate thus :

    Q-learning is particularly easy to set up and is model-free

    Solving for risk with Temporal differences

    ),,()1),((min),( tuxGtxfVtxV Uu

    y

    yxPxyxP 0),(,1),(

    ya

    yVyxPxarV )(),(),(min*

    y

    tt yyxPxrxV )(),(.),(min)(1

    ),().,(),(),(1 ayQyspasgasQ tt

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    Optimal control gives the big picture

    Control using investment

    mechanism for Capital at Risk deduction justifiable. give keys for allocation

    Joining bottom-up and top-down management

    clear rules of engagement for both operational and senior management on

    budget

    Remedy scarce data : How ? e.g by reinforcement learning,

    greedy algorithm: not necessarily CPU consuming

    by justifying online sampling

    compensate scarce "experience points" with observations-weight

    modifications (ANN like techniques - filtering) allow use of Monte Carlo by process even where no history was available

    Regulator oversight advantage

    secure model validation

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    Even if not solving to 100% it's setting the framework

    Separate roles of parameters from variables

    See role of Business Environment & Internal Control

    Adaptive learning

    Online sampling

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    Adressing gaps in today's risk management theory

    Temporal dimension :

    growth related risk (agressive strategies)planning

    Allocation problem : J = Jk

    Home Host

    business line arbitrage

    Adaptive :

    online sampling

    learning

    Operational Real Time hedging : future scanning with high quality

    inhomogenous Poisson time

    identification of chains of events as patterns