Operational Resilience: Reserve Bank of India's Guidance Note on ORM and OR Series
OR BB RBI Guidance Notes Sec 3-1

[OR] [RBI] [3] Three Lines of Defence for Management of Operational Risk

The RBI’s guidance emphasizes the critical importance of effective change management in mitigating operational risks. Financial institutions must establish a comprehensive change management process that involves all relevant departments and is supported by adequate resources. This process should thoroughly assess potential risks associated with changes, such as new products, systems, or markets.

The guidance reinforces the role of the three lines of defence in managing change. The first line is responsible for initial risk assessments, while the second line provides oversight and challenge. The third line independently reviews the change management process. To ensure adequate control, institutions should maintain detailed records of products and services and regularly monitor changes for any unexpected risks.

Ultimately, the RBI expects financial institutions to prioritize change management as a key component of their operational risk management framework to enhance overall resilience and protect against potential losses.

Moh Heng Goh
Operational Resilience Certified Planner-Specialist-Expert

Three Lines of Defence for Operational Risk Management

Effective operational risk management requires a collaborative approach involving three lines of defence. Business units are responsible for identifying and managing operational risks.

The operational risk management function provides independent oversight, ensuring risks are adequately controlled. The audit function independently assesses the overall effectiveness of the risk management framework, assuring the board.

RBI ORM and OR Guidance_Principle 5Principle 5: Comprehensive Three Lines of Defence for Management of Operational Risk

Effective operational risk management (ORM) relies on a robust three-lines-of-defence model.

RBI OR Diagram_Business Unit Management

Business Unit Management
First Line of Defence

The first line of defence is the business unit itself. It's responsible for identifying, assessing, and mitigating operational risks inherent in its operations.

This includes setting controls, monitoring risk profiles, and reporting operational losses and control deficiencies.

Organisational Operational Risk Management Function including Compliance Function
Second Line of Defence

The second line of defence is the organisational operational risk management function (OORF). It provides independent oversight and ensures that business units effectively manage operational risks.

The OORF develops policies, standards, and guidelines, challenges business unit assessments, and includes risk awareness training.

Audit Function
Third Line of Defence

The third line of defence is the audit function. It independently assesses the adequacy and effectiveness of the ORM framework. This involves validating risk quantification systems, verifying the design and implementation of ORM systems, and reporting findings to the board.

For the model to be effective, each line of defence must have clear roles, adequate resources, and strong communication. Ultimately, the seamless collaboration between these lines forms a robust shield against operational risks.

Note: This summary focuses on the core responsibilities of each line of defence. The original text provides more granular details and specific requirements.

 

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