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Outline how operational risk capital is allocated across business units.

FRM® Part I · Valuation and Risk Models · Operational Risk · FRM1.VR.7.h

The idea

Operational risk capital is first estimated for the whole bank and must then be allocated to business units, so that managers face a charge for the risk they generate and have a reason to reduce it. Allocating by gross income, as the basic indicator and standardized approaches implicitly do, is simple but ignores how well a unit controls its risks, so improvements bring no reward. Better schemes tie the charge to the unit's own loss experience and to scorecards built from RCSA results and KRIs, so that stronger controls lower the allocation. Stand-alone capital of the units usually sums to more than the bank-level figure because of diversification. A common method therefore scales each unit pro rata, as follows: Allocation = stand-alone capital × bank capital ÷ sum of stand-alone capitals. Beware allocating purely on reported losses, which encourages units to hide losses and near misses.

Formulas

Pro rata allocation of operational risk capital

allocationᵢ = stand-aloneᵢ × bank capital ÷ Σ stand-alone

stand-aloneᵢ
unit i's stand-alone capital
bank capital
the bank-level capital after diversification
Σ stand-alone
the sum of all units' stand-alone capitals

Every unit gets the same diversification discount. Allocation keys based purely on reported losses invite units to hide losses.

A practice question

From the question bank, with the reason each wrong option is wrong.

What is the main weakness of allocating operational risk capital to business units in proportion to gross income?

  1. It allocates more capital in total than the bank holdsWhy not: Proportional allocation always sums to the bank total.
  2. It cannot be applied because gross income is not reported by business lineWhy not: Gross income by business line is standard in Basel approaches.
  3. It ignores how well each unit controls its risks, so improving controls does not reduce its charge - correct
  4. It places too much weight on each unit's loss historyWhy not: Gross income is a size measure; loss history plays no role in this scheme.

A gross-income key is easy but is blind to control quality, so there is no reward for reducing risk.

A harder one

Stand-alone operational risk capital is USD 60 million for unit A, USD 90 million for unit B and USD 150 million for unit C. Bank-level capital, reflecting diversification, is USD 240 million. Allocating pro rata to stand-alone capital, unit C receives:

  1. USD 150 millionWhy not: Reports the stand-alone figure, ignoring diversification.
  2. USD 120 million - correct
  3. USD 80 millionWhy not: Splits the bank-level capital equally among three units.
  4. USD 90 millionWhy not: Subtracts the entire USD 60 million diversification benefit from unit C.

Pro rata: 150 / 300 x 240 = 120. Each unit gets the same diversification discount of 20 percent.

The hardest tier

Stand-alone capital is USD 80 million (unit A), USD 100 million (B) and USD 120 million (C), and bank-level capital is USD 255 million, allocated pro rata, so B receives USD 85 million. Unit B improves its controls and its stand-alone capital falls to USD 70 million; A and C are unchanged, and the ratio of bank-level to total stand-alone capital stays constant. B's allocation falls by:

  1. USD 30 millionWhy not: Takes the fall in stand-alone capital, ignoring diversification and the change in the pro rata base.
  2. USD 18.9 millionWhy not: Holds bank-level capital fixed at 255 and re-spreads it pro rata, ignoring the bank-level saving.
  3. USD 8.5 millionWhy not: Spreads the bank-level saving of USD 25.5 million equally over three units.
  4. USD 25.5 million - correct

Ratio = 255/300 = 0.85. New total stand-alone = 270, bank capital = 229.5. B new = 70/270 x 229.5 = 59.5; old = 85.0; fall = 25.5.

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