中央银行(监管者)操作风险管理的系统方法:先决条件、当前问题和发展前景

V. Goreglyad
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摘要

关于金融风险管理问题,在理论和实践上都已经有了相当广泛的研究。然而,当涉及到操作风险时,情况并非如此。这样做的原因并不在于两种类型的风险具有不同的重要程度(两种类型都可能对组织造成灾难性的后果);而是由于它们的性质不同,而且在操作风险的情况下,风险的来源和后果之间的因果关系更为复杂。这些情况使得评估和理解操作风险都极具挑战性。此外,尽管在商业机构面临的操作风险方面已经做了很多工作(这在很大程度上要归功于将其视为金融稳定问题的监管机构的努力),但直到最近二十年,监管机构本身(中央银行和其他监管机构,以下简称监管机构)才开始实施操作风险管理系统。本文分析了操作风险管理系统方法在国际实践中形成的先决条件,并对其适用于监管机构和商业机构的合理性进行了比较分析。我们的分析证实了这种新趋势的相关性,并表明,鉴于其具体性质,当监管机构在其活动中实施操作风险管理系统时,风险文化和自上而下的支持问题就会出现。
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Systematic Approach to Operational Risk Management in Central Banks (Regulators): Prerequisites, Current Issues, and Development Prospects
As regards financial risk management, its issues have already been worked through rather extensively both in theory and in practice. However, this is not the case when it comes to operational risks. The reason for this does not lie in the two types of risk having differing levels of significance (both types can have disastrous consequences for an organisation); it is rather due to their differing nature and, in the case of operational risks, more complex cause and effect relationships between the sources and consequences of risks. These circumstances make it extremely challenging not only to assess, but also to understand operational risks. Moreover, whereas a lot has already been done in regards to the operational risks faced by commercial institutions (which is largely thanks to the efforts of supervisory bodies who consider this a matter of financial stability), it is only in the last two decades that supervisory bodies themselves (central banks and other regulators, hereinafter referred to as regulators) have been seen to implement operational risk management systems. In this paper, we analyse the prerequisites for the formation of a systematic approach to operational risk management in international practices and conduct comparative analysis of its reasonableness for using by regulators and commercial institutions. Our analysis confirms the relevance of this new trend and demonstrates that, given their specific nature, when regulators implement operational risk management systems in their activities, risk culture and top-down support issues come to the fore.
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