Implementing the EU Capital Requirement Directive – key operational risk elements

Basel II and the EU CRD introduce, for the first time, specific Operational Risk requirements for credit institutions and investment firms. With less than 2 years available to prepare for the introduction of the simpler Operational Risk approaches, some firms would find it useful for the FSA to prescribe specific detailed Operational Risk standards that could be taken into account whilst preparing for the implementation of the EU Directive. However a variety of considerations, including differences between firms in terms of size, scale of activity and complexity and uncertainties over the final version of the Directive, will prevent the FSA from prescribing a detailed range of qualitative Operational Risk standards. This paper seeks to identify the general Operational Risk standards currently embodied in the Basel and EU documents and to distil these standards into ten qualitative Operational Risk elements that are likely to be considered by the FSA as part of any assessment of a firm's Operational Risk framework. Given the variables and uncertainties that will impact on the FSA's expectations for specific firms this paper reflects the authors' views and not the corporate views of the FSA.