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Article 7: Strategic and Operational Decisions

C 153-2018 STA Effective from 27/6/2018
  1. l. A bank must have approval procedures for new products, material modification to existing products and strategic or major operational initiatives such as changes in systems, business models or acquisitions. The procedures must ensure that strategic and major operational decisions require approval by the board or a committee of the board. Approval authority for new products or material changes to existing projects may be delegated by the Board to the appropriate level of management, although the Board remains ultimately responsible.
  2. 2. In addition to providing for reporting that enables the Board and senior management to monitor the associated risks on an ongoing basis, the procedures must include at a minimum:
    1. a. An assessment of risks under a variety of scenarios, particularly with more pessimistic assumptions than the base-line case;
    2. b. An assessment of the extent to which the bank’s risk management, legal and regulatory compliance, information technology, business line and internal control functions have the necessary expertise, systems and other tools to measure and manage the associated risks, if necessary withholding approval if the required measures are not in place; and
    3. c. An ongoing assessment of risk and performance relative to initial projections and if necessary adapting the risk management treatment in light of experience.
  3. 3. Mergers and acquisitions, disposals and other changes to bank or group structure can pose special risk management challenges. Risks can arise from conducting insufficient due diligence that fails to identity post-transaction risks or activities conflicting with the bank’s strategic objectives or Risk Appetite. The risk management function must be actively involved in assessing the risks of such transactions and must report its findings directly to the Board or a committee of the board.