Thursday, 28 April 2011

As promised - direction to FSA slides

The afternoon sessions of the FSA Sol II presentation on the 18th have now been added to their website. You can find everything here, but of more significance to me were the internal model panel session slides and of course the risk-specific presentation .

For the internal model presentation, important to note that this puts more flesh on the bones of the public statements on internal model in Hector Sants' and Julian Adams' speeches. Some particularly ropey diagrams used, so we know they are not wasting money on consultants! Further details on the one-size-fits-tiny people model approval process won't emerge until July.

Even more significant is the statement "external review" is qualified as "external to the FSA" - however they must be "suitably skilled", which rules out Internal Audit I would dare say - again, rollout of additional info in July, with a few lucky blighters piloting in the meantime.

For the risk, governance and data presentation, I was sad to see the comment on ORSA that "easier to say what it is than what it isn't" from the regulator - this is not my view at all, and betrays a certain lack of desire bearing in mind the riches to be found in the Level 3 papers. Again, plenty more in the way of dodgy diagrams and "holistic" planning (I can't be the only person who thinks of tie-dye t-shirts and alternative medicine when I hear "holistic" - "enterprise-wide" please people!).

Other than that, there was a lot of very simplistic terminology and recommendations, as if the perception was that a lot of organisations had not made progress in these fields, as well as a lazy attempt to stick Fukushima in as a case study. However, it redeems itself towards the end with a dashboard-type slide which may get some juices flowing in the risk functions across the land...

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