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Not Going to IBM Vision 2012? Better "Think Twice."
Timothy Powers 270003F3FN firstname.lastname@example.com | | Tags:  xbrl predictive-analytics governance decision-management risk grc business-analytics performance-management fraud compliance openpages clarity cognos analytics | 0 Comments | 4,290 Visits
Do you really understand the reasons you make decisions?
Sometimes the mind wants to unconsciously push us into a certain decision when there's a better way to think about it.
That's the premise of the book, Think Twice: Harnessing the Power of Counterintuition, written by Michael Mauboussin, Chief Investment Strategist at Legg Mason Capital Management and a keynote speaker at IBM's upcoming Vision 2012 conference in Orlando, May 14-17.
Vision is IBM's global conference for finance and risk professionals to help improve planning, budgeting and forecasting, identify and mitigate risk, and meet the demanding requirements of XBRL, IFRS, Basel II and Solvency II with greater confidence.
I talked to Mauboussin about his book, making data-driven decisions, some common pitfalls as decision makers, and his upcoming talk at Vision.
"What's very exciting is that in the last half dozen years, we've had a real influx of data, and we're now just learning how to tap that data for the benefit of better decision making," said Mauboussin. "Now we can create a better intersection between value creation and making decisions."
The problem however, according to Mauboussin, is that we still have the same cognitive makeup and the propensity to make common mistakes.
"We often think about our own decision making as being objective and fact based and rationale. And we tend to underestimate systematically how important the social context is for our decision making," said Mauboussin.
To illustrate this point he told an interesting story from his book.
Researchers went into the wine section of a supermarket and set up French and German wines next to each other that were roughly matched in price and quality. Over a two week period they alternated playing distinctively French and distinctively German music to see if it would have any influence on purchase decisions.
Surprisingly, they found when French music played people bought French wine 77 percent of the time, and German wine 73 percent of the time when German music played. When asked if music affected their selections, the consumers unanimously said no.
"This basic experiment can be extrapolated to a lot of organizational settings where we think of ourselves as trying to be conscious and mindful as we make decisions. But indeed what is going on around us can be deeply influential to our decisions," said Mauboussin.
So what do we do?
According to Mauboussin, integrate more data into quality decisions. However, there is still a tension between the intuitive, go by the seat of the pants experience group versus the analytically-minded group.
"Either extreme is not going to work but a blend between the two is right way," said Mauboussin.
Read the rest of the interview with Michael Mauboussin on the Business Analytics Blog here.
For more information:
· Register here for the upcoming Vision 2012 conference
· Download the Vision conference guide for background on keynotes, elective sessions, demos & workshops
· Read a previous blog post on minimizing risk and improving performance
Vision 2012, 1068 Managing IT Risk and Compliance with IBM OpenPages ITG
Erwin Boeren 270002C43V email@example.com | | Tags:  itg and 1068 governance with vision management compliance managing openpages it cloud grc risk ibm 2012 | 0 Comments | 4,190 Visits
Managing IT Risk and Compliance with IBM OpenPages ITG (Track 1068)
At IBM Vision 2012, Tuesday May 15th, 1:15 – 2:15 pm I will be presenting Managing IT Risk and Compliance with IBM OpenPages IT Governance.
In this session I will take you through the results of the IBM CIO Study 2011 that was recently published and guide you through the IT Risk related subjects.
Do you want to understand how Big Data, Cloud, Regulatory Pressure, Business Continuity Management, Disaster Recovery, Identity and Access Management, Segregation of Duties, Automated Controls and Endpoint Controls will influence your GRC strategy?
This all comes together in IBM Smarter IT Governance, Risk and Compliance.
Hope to see you in Orlando next week!
Twitter : #Vision12
Blog post by Erwin Boeren
Senior Governance, Risk & Compliance specialist IBM
Twitter : http
LinkedIn : http
Convergence of Performance Management and Risk Management - Part 2
Erwin Boeren 270002C43V firstname.lastname@example.com | | Tags:  grc risk reporting ibm compliance fsr cognos solvency regulatory ii basel openpages | 0 Comments | 3,892 Visits
Convergence of Performance Management and Risk Management - Part 2
the increase of the Governance, Risk & Compliance maturity level at many of
my clients I see that clients start to realize the benefits of the integration
of GRC activities in their Performance Management cycle. Therefore a follow up
on my previous article around Risk Management and the convergence with
Performance Management.
Let me share some insights on Risk & Performance Management initiatives that keep clients busy around Europe. The following 4 items came up in the last 3 months.
1. Cost control and process performance improvement give us the opportunity to embed controls in our process. Lessons learned from Six Sigma and Lean can give us guidance here.
2. How do I manage organizational and regulatory change and monitor the impact on business processes, policies and my risk and control framework?
3. Trending topic is emerging risks, am I able to identity risks that are coming to me over time?
4. Integrated Financial and Risk reporting, an excellent example of 'Where Performance Management meets Risk Management'.
Cost control and Process improvements
Implementing and testing controls has become a huge cost for many organizations. That is why some of my clients are now looking for a way to reduce cost by embedding controls in their existing business processes. This goes hand in hand with the global initiative on cost reduction. While optimizing or even re designing core business processes internal controls are being embedded in the process. What I see is that the organizations that involve process owners and process contributors are most successful. This is an initiative that we have seen before in Lean Six Sigma projects. The only way to optimize processes and to reduce waste is to involve the process owners. Instead of increasing regulatory pressure we should seek a solution in this area in my opinion. Business cases around this have proven to be very successful and savings up to millions of Euros per year have been achieved.
Regulatory change
Regulatory changes are a huge concern of many risk, compliance, legal and audit professionals. How can we monitor these changes and how can we understand the impact on our organization? Taking this together with the fact that policy management is changing from a 'must do' once a year to a continuous process tells us that an integrated approach to Governance, Risk & Compliance is necessary to drive performance. I come across clients that have a monthly Performance Report that shows how they derived business objectives from their policies and how they are performing on a compliance level to these objectives. What risks did they identify in this process and how will they respond to these risks? Organizations realize that they need to understand the correlation between processes, policies, regulations, business objectives, risks and controls and how they might impact each other. An integrated GRC view is the only way to face this challenge.
Emerging Risk Modelling
One of the trending topics among customers is Emerging Risks. Can we model risks that we see coming and can we follow up on risks that are getting closer or fading away? Analytical Risk modeling is an answer to this question. This also let you perform risk forecasting with different scenarios. Interesting question is how the increase of a risk exposure in an operating entity will impact my group level exposure? Risk Analytics, derived from the Performance Management area can help us answer these questions. A financial performance management cycle contains the exact same characteristics.
Integrated Financial and Risk performance reporting
Financial and Risk reporting are standard items in today's Annual Reports, Tax statements, Management reports and Regulatory reports. The big question is how do I keep all of this information organized in such a way that I understand the source of the information, the transformation it has gone through, the owner of the information and most important when information changes at the last moment that all information output contains the latest version? No bigger reputational risk than sending out inconsistent information to stakeholders. Some organizations saw their share price drop with 25% due to inconsistent external reporting. One of my clients has implemented a solution that orchestrates all of these information sources with workflow capabilities and even XBRL output. From a risk perspective this is a great mitigation of your reputational risk and an excellent example of 'Where Performance Management meets Risk Management'.
Blog post by Erwin Boeren
Senior Governance, Risk & Compliance specialist IBM Europe
Twitter : http
LinkedIn : http
Impact of Big Data, Cloud, Mobile and Regulatory Pressure on your IT Risk and Governance Model
Erwin Boeren 270002C43V firstname.lastname@example.com | | Tags:  value solvency cio risk ibv openpages insurance of institute ibm business it governance basel bank grc compliance | 0 Comments | 3,849 Visits
Impact of Big Data, Cloud, Mobile
and Regulatory Pressure on your IT Risk and Governance Model.
This 30% decrease was established by optimizing and
automating the risk process, end users are now able to complete the whole risk
cycle in one platform with risk identification, risk assessment, risk
management, risk reporting (real time!) and risk monitoring.
2. Customer decreased their manual IT control test
effort with 140 hours per week only for Segregation of Duties and access
management. This was done by automating control tests.
Blog post by Erwin Boeren
Senior Governance, Risk & Compliance specialist IBM Europe
Twitter : http
LinkedIn : http
SEC Expanding Compliance Investigations to Boards of Directors
Richard Steinberg 270004HRBG email@example.com | | Tags:  compliance openpages ocie sec | 0 Comments | 3,811 Visits
The head of the SEC's Office of Compliance Inspections and Examinations, Carlo di Florio, recently spoke about what his 900 professionals look for in conducting examinations of a wide range of financial institutions – noting the OCIE is breaking new ground. In carrying out its mission to improve compliance, prevent fraud, monitor risk, and inform policy, di Florio's office is expanding its focus to include boards of directors. In considering a firm's compliance culture, the OCIE is entering into direct discussions with boards of directors, to get a sense of the board's as well as senior management's attention to and focus on regulatory compliance issues. di Florio didn't name names, but media reports say such discussions already have taken place with the likes of Goldman, Morgan Stanley, Barclays and Wells Fargo. He did say that the new focus is due in part to the fact that a firm's compliance culture is an "elusive concept and a real challenge," having a huge impact on the extent to which a firm engages in ethical conduct, also noting the need to integrate compliance within risk governance processes.
If you've encountered Carlo di Florio, you may have observed a soft spoken, gentle demeanor and charming personality. But that shouldn't be misinterpreted for anything less than a hard-nosed and rigorous approach on the part of him and his staff. Having worked with him in our "past life," I can assure you that he is not only thoughtful and creative in approach, he can be relentless in pursuing objectives.
OCIE's approach is multifold, focusing first on review of a firm's polices and related procedures, including policy management and flexibility in dealing with evolving conditions. There's focus on effectiveness of communication and training, and on such matters as how a firm assigns responsibility and handles accountability. Also in its sights are monitoring and testing processes, protocols for communicating issues upstream, and internal whistleblower processes. di Florio notes that the better the internal processes, the less OCIE will need to do. Highlighting its insightfulness, OCIE looks at such critical matters as where the power lies – the business side or legal/compliance – how bonus pools are allocated, independence of compliance staff, and involvement in critical decision-making. Also, the extent of compliance contributions of business units in performance assessment and reward processes are considered.
With all this, the focus on board of directors is consistent with attention to the tone at the top of a firm. Carlo di Florio is moving the lines, and I've no doubt he and his staff will have a sharper focus on and greater insight into what drives compliance.
Looking back at a great IBM Vision 2012, Orlando FL
Erwin Boeren 270002C43V email@example.com | | Tags:  risk 2012 openpages grc governance basel solvency ibm vision | 0 Comments | 3,712 Visits
Looking back at a great Vision 2012,
Vision 2012 was a great event with many customers speaking, partners and market analysts.
Customer Advisory Board
The IBM Customer Advisory Board came together in Monday, the day before the event officially kicked off to discuss the IBM Integrated Risk roadmap and to prioritize future development initiatives.
Keynotes were presented by Les Rechan (General Manager IBM Business Analytics), Mark Loughridge (CFO IBM) and Alison Levine.
Les opened with an energy level high as always! Mark gave a great insight in the financial transformation IBM has gone through and the road ahead. Alison delivered a key note where the whole room hung on her every word. Astonishing how Alison can present and what an inspiring lady she is.
this is available in recordings on : http
OpenPages version 6.1 released
At the risk keynote on day 1 by Patrick O'brien and Gordon Burnes the new version 6.1 of OpenPages was released. New features can be found on the IBM OpenPages 6.1 landing page :
A new leader for the IBM Risk Analytics pillar
Michael Zerbs has been appointed as the new leader to run the IBM Risk Analytics organization. Michael was the President and COO of Algorithmics. He is a recognized expert in risk management for market and credit risk, and has an in-depth understanding of the key risk management challenges that the financial industry faces today. He has authored several papers on pricing models and risk management and is a co-author of Mark-to-Future: A Framework for Measuring Risk and Rewad.
Market Analysts impressed by IBM Risk Portfolio
analysts could be found in
Operational risk is still strong as ever but Policy & Compliance management, IT Risk & Governance and Audit capabilities have grown to such maturity level that IBM is top in Risk Analytics.
Customers are expanding on their GRC Environment
Clients speaking at the 2 main event days were all expanding their platform to multi discipline risk. Especially risk convergence, standardization, enterprise risk management, IT Risk & Compliance and Fraud & Financial Crimes were topics that came across many times.
IBM implemented OpenPages
IBM has implemented OpenPages herself, and demonstrated that at day 2. Deborah Dunagan, IBM Transformation Executive demonstrated how IBM reduced her risk cycle times with 30% using IBM OpenPages!
With all this excitement we are looking forward to another great year and client success in Risk Analytics.
Blog post by Erwin Boeren
Senior Governance, Risk & Compliance specialist IBM
Twitter : http
LinkedIn : http
IBM Enhances Risk-Aware Decision Making & Policy Management with New OpenPages Platform Release
Timothy Powers 270003F3FN firstname.lastname@example.com | | Tags:  frank-dodd risk grc business-analytics cognos fraud performance-management compliance openpages analytics governance risk-analytics | 0 Comments | 3,624 Visits
By Gordon Burnes, Worldwide Marketing, IBM Risk Analytics
A key theme at Vision 2012, IBM's three-day user conference for Finance and Risk professionals, is how organizations can leverage enterprise risk information to make better decisions while balancing the demands for risk oversight and regulatory compliance.
The current complex and dynamic regulatory environment is a particular challenge for risk and compliance directors. For instance, while organizations covered by Dodd-Frank must respond to current regulatory reporting requirements, less than a third of the associated rule-making has been finished.
So, risk and compliance professionals must put in place an approach to meet regulatory requirements that can easily adapt over time as regulations evolve, and this approach includes the capability to adapt internal policies to keep pace with the evolving regulatory environment.
During the Risk Analytics Keynote, IBM announced general availability of IBM OpenPages GRC Platform 6.1.
This new solution enhances the ability to make risk-aware business decisions, enables companies to react more quickly to regulatory changes through better policy management, and decreases costs and complexity of compliance.
Leveraging the IBM Cognos business intelligence platform, OpenPages 6.1 delivers interactive reports and dashboards that allow business managers to turn that risk information into insight and insight into better business outcomes.
The new release includes several important enhancements:
· Manages lifecycle of policies from creation, review, approval, attestation, and exception management
· Standardizes policy templates and approval processes across the business
· Allows policies to be structured in a standardized way but presented in narrative form (for editing and review, etc) the way people are used to working with policies
· Formalizes process for employee awareness and training and monitoring of campaigns
· Maps policies to regulatory library and control framework to increase visibility into policy coverage & adherence and make it easier to update policies as regulations change
· Enhanced reporting user interface and framework that empowers business users to explore and analyze risk data using interactive dashboards and reporting for better decision making
In summary, IBM OpenPages 6.1:
· Enables companies to react more quickly to regulatory changes through better policy management
· Enhances the ability to make risk-aware business decisions through easier access to risk and compliance information
· Decreases the cost and complexity of compliance with out-of-the-box configurations for policy management.
For more information:
· Read the Vision 2012 Day One Recap
· Read the blog post from Michael Zerbs, VP of IBM Risk Analytics, "Managing Risk: A Global Challenge that Must be Confronted"
· Download the whitepaper, "Managing Regulatory Change - Learn how Dodd-Frank Impacts Regulatory Compliance"
· Follow @IBMRisk & @IBMCognos on Twitter and/or search #Vision12
For more information:
· Read the Vision 2012 Day One Recap
· Read the blog post from Michael Zerbs, VP of IBM Risk Analytics, "Managing Risk: A Global Challenge that Must be Confronted"
· Download the whitepaper, "Managing Regulatory Change - Learn how Dodd-Frank Impacts Regulatory Compliance"
· Follow @IBMRisk & @IBMCognos on Twitter and/or search #Vision12
Convergence of Governance, Risk & Compliance, Basel II and Solvency II (Track 1014)
Erwin Boeren 270002C43V firstname.lastname@example.com | | Tags:  openpages & risk of (track governance solvency ii convergence management 1014) and grc basel compliance | 0 Comments | 3,582 Visits
Convergence of Governance, Risk & Compliance, Basel II and Solvency II (Track 1014)
IBM Vision 2012, Tuesday May 16th, 16:45 – 17:45 pm I will be presenting the Convergence
of Governance, Risk & Compliance, Basel II and Solvency II.
In this session I will take you through the most common questions I received from our customers facing Basel II and Solvency II. I will help you understand the challenges from an Operational Risk perspective and speak about how my clients have overcome these challenges.
Convergence, Risk Adoption, Risk Montoring, Loss Registration, Risk Reporting
and Dashboarding and Regulatory Reporting are topics that will be discussed in
this session.
Hope to see you in Orlando next week!
Twitter : #Vision12
Blog post by Erwin Boeren
Senior Governance, Risk & Compliance specialist IBM
Twitter : http
LinkedIn : http
Opposite Ends of the FCPA Spectrum
Richard Steinberg 270004HRBG firstname.lastname@example.com | | Tags:  morgan compliance fcpa stanley grc wal-mart openpages sec | 0 Comments | 3,496 Visits
Chief Compliance Officers, General Counsels and other business executives have long been pushing regulators to provide clarity around the FCPA and more consistent (and appropriately fair) enforcement. Well, companies finally have something reasonably definitive to look at which shows how a well-constructed compliance program implemented in good faith can have extremely positive consequences – it's the recent Morgan Stanley case, which we'll get to in a moment.
At the other end of the spectrum is the Wal-Mart fiasco. You know the story – senior Wal-Mart executives knew of millions of dollars being paid to government officials in Mexico to aid expansion in that country, but shut down an investigation. The Justice Department and Securities and Exchange Commission are all over this, and things will not go well for the company. The last thing the DOJ or SEC looks favorably on is executives not reporting a suspected or known violation, and not conducting a full and comprehensive internal investigation. Now proxy advisory firms ISS and Glass Lewis, as well as major public pension funds, are recommending that Wal-Mart shareholders vote against members of the board of directors for neglecting their responsibilities. And there are indications the bribery might extend beyond the Mexican subsidiary. The stock price has taken a hit, the company faces potentially huge fines, executives could wind up in prison, and investors are suing. As is often the case, it's not so much the bad action, but the cover-up. And it's also whether the system, here the compliance process, was well designed, implemented and maintained.
Now to Morgan Stanley. The DOJ and SEC have long said that in enforcement actions they give credit to companies for already having a good compliance system in place, but we've seen little direct evidence of that. But now we have a game changer. The problems at Morgan Stanley reportedly arose when Garth Peterson, a managing director, successfully pushed for the firm to sell a real estate interest to a Chinese state-owned company, but it turned out to be a shell company in which Peterson had a direct interest, with related cash payments to himself and a Chinese official. Peterson pleaded guilty, facing a potential six-figure fine and five years in prison. But what happened to Morgan Stanley, or didn't, is the real story here. The DOJ and SEC decided not to bring an enforcement action against the company. The reason – Morgan Stanley has had a strong compliance system, including relevant internal controls. It regularly updated controls to reflect risks of misconduct, and provided extensive training to its personnel, compliance reminders, annual confirmations by personnel, and continuous monitoring. And, when evidence of misconduct surfaced, the firm immediately began and conducted a thorough investigation.
So, there we have two well-known brand-name companies, one of which is likely to pay a high price, the other none at all and whose reputation is enhanced. The message now is clearer than ever. Engage in a cover-up, and deal with forceful regulators and angry shareholders. Have an effective compliance system and do the right thing, and the regulators and others will indeed look favorably upon the company.
Risk Reporting and Dashboarding now available on your desktop!
Erwin Boeren 270002C43V firstname.lastname@example.com | | Tags:  ibm solvency insight dashboarding governance grc openpages management reporting risk basel cognos ii compliance | 0 Comments | 3,287 Visits
With the brand-new IBM Cognos Insight you can now connect to your IBM OpenPages environment from your desktop. You always have that moment that you need the information on a report but just a bit different than the standard report provides to you. The solution is here now, IBM Cognos Insight!
Insight is a powerful, intuitive desktop solution, that can read many different data sources from Excel to datawarehouses. Even your real time IBM OpenPages environment!
And it is not only reporting and dashboarding but it also lets you create what if scenarios on the fly! How would my risk exposure be if in one risk category the loss impact increases with 15%? Two clicks and you know the answer! And then you can comment on your report, which gives your colleagues more information on the context the moment you share your workspace.
How easy can risk reporting be???
For more tour on how IBM Cognos Insight please look at : http
Blog post by Erwin Boeren
Senior Governance, Risk & Compliance specialist IBM
Twitter : http
LinkedIn : http
COSO in the Cloud
Richard Steinberg 270004HRBG email@example.com | | Tags:  openpages erm risk itg it-risk coso risk-management | 0 Comments | 3,198 Visits
If you haven't already seen it, it's worth a look – The Committee of Sponsoring Organizations of the Treadway Commission just published a thought paper dealing with risks related to cloud computing. It leverages off COSO's enterprise risk management framework, speaking specifically to issues surrounding hosted services delivered over the internet. The paper is geared not to the techie, but rather to management level personnel who need to understand not only the benefits, but also the associated risks. The paper briefly outlines the many benefits of cloud computing, including greater technology value at lower cost, faster speed of deployment, common technology platforms, reduced need for support personnel and related expenditures, and environmental benefits.
Naturally, most of the focus is on the risks. These include the strategic – with lower barriers of entry for new competitors and related challenge to current business models – and dependency on cloud service providers which in turn drives legal and related risks. Others include lack of transparency, reliability and performance issues, security and compliance concerns, and elevated risk of cyber attack or data leakage. The paper also deals with issues inherent in moving to the cloud, such as the extent to which management considers the impact on the company's organization and IT and other personnel resources, noting "In many cloud scenarios, the organization no longer has complete or direct control over technology and technology-related management processes. Management must determine if it has the risk appetite for the entire universe of potential events associated with a given cloud solution as some of these events extend beyond the organization's traditional borders and include some events that have an impact on the [cloud service provider(s)] supporting the organization."
The paper also discusses cloud issues in the context of COSO's ERM Framework's eight components, outlining how each can be addressed and used in evaluating cloud computing alternatives. It provides suggestions for dealing effectively with the more significant risks, and highlights key decisions to be made by senior management – as well as responsibilities of C-suite executives – and areas on which the board of directors needs to focus its attention. If your company is already in the cloud or considering going there, the paper is worth the read.
How to make the right GRC software selection?
Erwin Boeren 270002C43V email@example.com | | Tags:  compliance enterprise egrc iii management grc software solvency audit selection openpages risk tooling governance ii basel and | 0 Comments | 3,149 Visits
Governance, Risk and Compliance software selection process
A client of mine recently asked me about what I have seen as the most effective way to run a selection process. Now I know this may seems a conflict of interest, a GRC solution vendor writing on the GRC software selection process and the need for a GRC platform. Still I think I can give you some dos and donts on a GRC software selection process since I have been there many times.
Let's start with the need for a GRC software platform. Why do you need such?
Of course investing in a solution needs a compelling event. Either the cost for risk management and compliance becomes very high, or the process takes too long to be responsive to stakeholders or the 'in control' statement cannot be guaranteed any longer. Also external regulators can advise you to implement software.
Before you start thinking about a GRC platform carefully review the risk and compliance maturity level of your organization and the scope of the problem. This will help you make the judgment between 2 approaches. First approach is what we call 'point solution', second approach is 'enterprise solution'.
The first approach, Point Solution, is best when the compelling event is there but the scope is limited to one area. On a single point of your GRC activities you have a pain that must be resolved in a fairly short term. In this case you can search for specific capabilities with specific knowledge. You can make a selection of vendors that operate in the area where you have the pain and select the partner that understands your area. Of course you might want to consider your ambition on the long term. If your long term ambition is Enterprise wide GRC integration you might still look at enterprise vendors and use the specific area as a 'pilot' for further extension.
The second approach, Enterprise Solution, is best when the compelling event is on the integration of Governance, Risk and Compliance. The term risk and control convergence often comes up here. This approach requires a lot more work than the point solution and may have cultural impact. You might consider a second party to help you go through this project. A second party (consulting firm) can help you in making critical decisions and in reviewing your current (silo based) approach to GRC. They can keep the holistic view for you. Every silo needs to be reviewed and mapped to the enterprise approach. This will not come without discussions and sacrifices!
So the need is there, now how to make your selection?
In the first point solution approach there are just two considerations, short term or long term? In case of the short term do NOT select an enterprise vendor and go for the right point solution. Advantages are lower cost and shorter implementation time. Second consideration, long term, means a selection between enterprise GRC software vendors and consider the first phase as a pilot for the enterprise approach. Still you might want to involve a consulting firm with specific knowledge.
In the second enterprise approach you will go for an enterprise vendor. This is where you want to be careful in setting up your selection. I personally have seen many of these selection processes since I have been in such selections. And this is where I want to give you some guidance to save you a lot of time and money.
First do NOT expect the enterprise vendors to differentiate on functionality. The GRC software market has made an evolution in the last 10 years that have resulted in a fairly high mature software market. So a 'beauty contest' is a waste of money and resources. Outcome will be equal for all vendors and you will be stuck between your user community and the vendors in the process. You might get questions from your management team why you spend so much time and resources without any outcome.
Secondly involve your end users in the selection process early, but do not expect 20 people working in silos to come to one single conclusion. Again you will end up in a long discussion with no outcome. Have a small group of people (3 preferably) to make the selection.
Thirdly make your selection criteria known upfront and make them measurable. Also involve the vendors in the process and be open to them. If you are open and honest you will get transparent, open and honest answers. If you hide, vendors will hide! Criteria should be based on experience in your market, understanding of your organization, size and financial stability, ability to deliver in time and within budget, alignment of implementation approach to your implementation methodology and the cultural fit.
Again this may look preaching to the choir but I hope I just saved you time and money that you can invest in your implementation.
Blog post by Erwin Boeren, Senior Governance, Risk & Compliance specialist IBM
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Are Changes to FCPA Enforcement on the Horizon?
Richard Steinberg 270004HRBG email@example.com | | Tags:  openpages compliance sec fcpa | 0 Comments | 3,062 Visits
We know the Justice Department and SEC in recent years revved up enforcement of the Foreign Corrupt Practices Act, which certainly has gotten the close and widespread attention of the business community. With the vast majority of U.S. companies large and small operating globally, general counsels, compliance officers, boards of directors, and other business executives are focusing on related risks and controls. And now the U.S. Chamber of Commerce's Institute for Legal Reform, noting that companies want to comply with provisions of the FCPA but unclear enforcement makes it challenging, thinks "it is common sense that the rules of the road are clarified." As such, the Chamber has put forth five recommendations: Adding a compliance defense, limiting liability for the prior actions of an acquired company, adding a "willfulness" requirement for corporate criminal liability, limiting liability for acts of a subsidiary, and defining what constitutes a "foreign official."
It appeared these proposals might gain some traction, and then along came Wal-Mart. The charges of bribery in Mexico and subsequent cover-up seems to have dampened interest in modifying, or some would say softening, the FCPA and related enforcement. Certainly Wal-Mart has put tremendous effort into successfully lobbying legislators in both parties – and supporting the President's initiatives in health coverage and pollution control, and the First Lady's on healthy foods to combat childhood obesity – all of which may serve the company in good stead in containing political fallout. But we can also expect notoriety around the Wal-Mart case to signal the continued relevance of the Act and deflect efforts to weaken it.
It seems there's an interesting analogy here, where the Wal-Mart bribery case might be to the FCPA what WorldCom was to Sarbanes-Oxley. After Enron imploded, there was stirring inside the Beltway about need for legislation, but nothing much was expected to happen – until a few months later when the WorldCom fiasco hit the headlines, thereby generating momentum that turned into a rush to get a law passed. In this instance, it may well be the converse – a law that might have been weakened is more likely to stay as is, with continued strong enforcement by regulators. We'll stay tuned to see what transpires.
Compliance Problems Continue in a Niche Industry
Richard Steinberg 270004HRBG firstname.lastname@example.com | | Tags:  openpages education risk-analytics compliance risk-management risk | 0 Comments | 3,044 Visits
You may remember hearing about problems with the College Board, which owns the SAT, and the Educational Testing Service (ETS), which administers the tests. In the recent SAT cheating scandal the College Board and ETS were accused of having lax security and a system that failed to punish cheats. But problems go back further, when a couple of years ago the SAT has serious issues with incorrect scoring of tests. And media reports speak to extensive incorrect scoring and losing test results in England in 2008, with the UK Parliament calling their operation a "shambles." And as far back as 1983 cheating was suspected in California. For details you may want to refer to my blog posting of November 2011, which includes analysis of what the accused organizations did, or rather didn't do, to right the wrongs.
Well, we now find another player in this industry accused of wrongdoing. Princeton Review, which provides help to students in preparing for college entrance exams and sells study guides, finds itself accused of defrauding the federal government. An arm of the company that provides after-school tutoring to students at troubled schools is said to have falsified records – including forging student signatures, falsifying sign-in sheets, and making false certifications – in order to boost payments due the company. Relevant is that the company was informed of these allegations back in 2006, but prosecutors, who are now suing, say the fraud continued as nothing was done to fix the system. For what it's worth, Princeton Review reportedly closed its tutoring division and says most of its current management joined the company after the alleged fraudulent activity took place.
But what's striking is how the few players comprising this industry have had serious problems – not only in allowing fraud to occur, but also in failing to act in the face of wrongdoing. And this is an industry supposedly driving high academic standards! Yes, we know academic institutions are not immune to misconduct, but we can wonder how these industry players each went so very wrong. And food for thought – do we see other industries with an inordinate number of companies experiencing widespread instances of non-compliance, fraud or other misconduct? And what does that say about the culture not only of the individual organizations, but the industry as a whole? Hmmmm.
Compliance Officers Stretched to the Limit
Richard Steinberg 270004HRBG email@example.com | | Tags:  risk-management dodd-frank compliance openpages | 0 Comments | 2,863 Visits
As a compliance officer, you're dealing with increased regulation and expectations, while related resources are subject to budgetary constraints. Yes, senior managements read the headlines and recognize the reputational and related risks associated with legal and regulatory compliance. But what I and others see are compliance functions having to do more, often without a commensurate increase in resources.
These observations are consistent with a recent Thomson Reuters survey of financial services companies' compliance professionals. The survey shows that compliance officers are struggling to keep up with increasing demands of global regulation – where rapidly growing regulations and increasing responsibilities, together with limited resources and constrained budgets, are causing compliance personnel to reached a "saturation point." A whopping 84 percent of respondents say they expect to deal with more information from regulators and exchanges this year, with almost half expecting the level to be "significantly higher." The increase is expected to come from such events as splitting of the U.K. Financial Services Authority, added regulatory power of the European Supervisory Authorities, expansion of new and existing U.S. regulatory agencies resulting from Dodd-Frank, and expanded enforcement of such regulations as the U.K. Bribery Act and the U.S. Foreign Account Tax Compliance Act.
The survey results show that compliance responsibilities and expectations are diverging from realistic capabilities. For instance, with a key objective being to coordinate with other company professionals involved with regulatory risk, over half of compliance professionals say they spend less than one hour weekly with internal audit colleagues, and one third spend less than one hour per week with legal and risk professionals. And while 70 percent of respondents expect the cost of senior compliance staff to increase this year, only 11 percent of companies expect a significant increase in budgets.
Also interesting in the statement that: "While keeping executive management informed of regulatory issues is a key part of the compliance role, more than a quarter of respondents say they spend less than one hour a week reporting to their boards. In the U.S., more than half of the companies surveyed spend less than one hour a week reporting to their boards. This raises concerns about whether executive management is being kept sufficiently informed on compliance issues." Well, it's not entirely clear from this as to the extent of interaction between compliance officers and senior management – one hour a week with the board may be just fine, as long as there's significant interaction directly with executive management.
In any event, what we see is compliance departments already working at a fast pace with high efficiency, but they face risks going forward if responsibilities and resources aren't recalibrated to be in sync.
Independent researchers positive on IBM's approach to Risk Management
Erwin Boeren 270002C43V firstname.lastname@example.com | | Tags:  grc research openpages enterprise algorithmics ibm management risk | 1 Comments | 2,800 Visits
In the last 2 months three independent researchers have given their opinion on IBM's approach to risk management. All 3 are very positive towards the areas of Innovation, Market Presence, Functionality and Enterprise GRC capabilities.
Forrester in the Forresterwave EGRC 2011: The OpenPages platform remains one of the most consistently strong enterprise GRC platforms on the market today. The company's vision is to enable senior management to make strategic risk and reward decisions to improve business performance and reduce exposure to risks and loss on investments. The OpenPages platform's GRC management and analytics features are just one example of where this mission will play out."
Gartner in its September update: The OpenPages platform has solid capabilities in all the core functions, has above-average support for ERM and ORM, and is rated very high on financial reporting integrity compliance. It continues to execute consistently on a well-planned road map."
Chartis published its Risk Top 100 last November with IBM ranked the No.1 vendor in the area of Risk Management. With special rewards for Functionality, Market Presence, Innovation, Fund & Asset Management, Market Risk, Operational Risk and Enterprise GRC.
In the Chartis RiskTech 100 IBM was measured for the first time along the qualitative and quantitative risk capabilities (read the acquisitions of OpenPages and Algorithmics). In the Gartner and Forrester publications the latest Algorithmics acquisition was not taken into account.
Interesting enough researchers praise IBM for immediately adding value to its acquisitions. One year ago IBM was ranked number 7 in the RiskTech 100 and now IBM is on top of the list. Not because the individual products are that good but because the minimal overlap and immediate integrations create added value for customers.
Adding Risk to the area of Business Analytics (Business Analytics is one of the 4 key initiatives of IBM towards 2015, driven by our new CEO Gini Rometty) is a great step into Smarter Risk. Capabilities like predictive intelligence, driver based planning, regulatory reporting, scenario testing, forecasting, dashboarding, scorecarding, reporting and analysis will give a great boost if you apply this to risk. This is where the convergence of performance management and risk management create great value for our customers.>
Blog post from Erwin Boeren, Governance Risk & Compliance Leader IBM Europe
GRC Maturity: From Disorganized to Integrated Risk and Performance - Part IV
Liz Andrews 2700041WEU email@example.com | | Tags:  compliance risk openpages grc | 0 Comments | 2,165 Visits
Getting to the Head of the Class: Advancing Your Organizations GRC Maturity
Organizations with GRC processes siloed within departments operate at the Unaware, Fragmented, or Integrated stage. At these stages GRC may be effective within a silo, but lacks an enterprise perspective of risk and compliance and gains no efficiencies from shared processes. Different departments may be at different levels of maturity.
The Aligned and Optimized maturity levels represent maturity of organizations with an enterprise GRC strategy, focused on developing a common GRC process, information and technology architecture. These organizations report process effi
Considerations for Moving From Fragmented to Integrated
Departments at the Fragmented stage have siloed approaches to risk and compliance at the department level. This means no integration or sharing of risk and compliance information, processes or technology.
To move from Fragmented to Integrated requires the department reduce manual data integration and improve overall visibility into risk exposure. Organizations should consider defining GRC process and information architecture at the department level and implement technology to manage multiple risk and compliance initiatives cohesively.
Considerations for Moving From Integrated to Aligned
Departments at the Integrated maturity stage are in a good place to lead the organization in an integrated GRC strategy to the Aligned stage. They have a strategic approach to GRC at the department level, supported by mature GRC processes that can be extended to other departments. These organizations have a shared-services approach to GRC to deliver common processes and integrated information.
To move from the Integrated to the Aligned stage requires a common risk catalog that shows the relationship of risks across the business and risk ownership. The purpose is to enable the business to make risk-informed decisions. Orga
Considerations for Moving From Aligned to Optimized
To difference between the Aligned to Optimized stage is primarily one of context. At the Aligned stage the orga
Achieving the Optimized stage requires GRC expectations set as part of the annual strategic planning processes. The organization has extensive measurement and monitoring of GRC in the context of business strategy, performance and objectives. There is shared information and technology between risk, control and compliance management as well as decision support, optimization and business intelligence. The organization has integrated risk and finance data to drive performance and maximize value creation.
Fundamental Steps to Establishing Your GRC StrategyTo achieve the benefits other organizations have seen from a GRC strategic plan and common approach, Corporate Inte
Smarter Project Risk
Erwin Boeren 270002C43V firstname.lastname@example.com | | Tags:  compliance grc governance manufacturing smarter energy&utilities openpages risk enterprise deloitte project | 0 Comments | 2,108 Visits
Smarter Project Risk
Last week I came across project risk, and not for the first time! So, time to spend some words on this topic.
Especially organizations in Energy&Utilities and Manufacturing have huge risks in their assets and in their projects. You think you have all risks identified through the standard risk identification process and you just missed that elephant?! This might impact your yearly financial result or worse!
This is why more and more clients start to look at Project Risk methodologies. My client happened to use the PMBOK methodology. In this methodology you consider standard project phases including standard risks and controls. This is great, since you have most of the standard risks covered. But what about that risk that is just not standard? This is where gate reviews will help you. These gate reviews are held after every project phase. Each gate review contains questions used to identify risks, holds monitoring methodologies to check status and behavior and contains audit like activities. Key element here is that all findings roll up to top level so no significant risk can be missed.
all works for what we call manageable risks, but what about risks that you
cannot manage? How will you anticipate on this? Well these risks can be covered
by sensitivity analysis, simulations and business continuity management.
Especially sensitivity analysis and business continuity analysis will help you.
For simulations you will need data, and a significant amount of data. Only in
case you have many similar projects running in a regular cycle you will be able
to generate enough risk identifications and losses to be able to make a sensible
calculation like
Now the system is in place, and now we are in control? Wrong! This is where the real work starts. How do I get my organization to adopt risk in her daily business? How do I get input with the right quality? How do I make everyone a risk manager? This takes time and effort. Guide your people in how to make the assessments and make them part of it. Give them back where they contributed to, and make their life easier. That is what we call Smarter Risk.
IBM OpenPages and Deloitte have put together a Risk Methodology for project risk where all these technologic and organizational aspects come together and can be integrated in your enterprise risk platform.
Blog post by Erwin Boeren
Senior Governance, Risk & Compliance specialist IBM
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LinkedIn : http
Solvency II and the need for Operational Risk
Erwin Boeren 270002C43V firstname.lastname@example.com | | Tags:  risk operational grc compliance ibm openpages solvency governance | 0 Comments | 1,910 Visits
Solvency II and the need for Operational Risk
Blog post from Erwin Boeren, Governance Risk &
Blog post from Erwin Boeren, Governance Risk &
GRC Maturity: From Disorganized to Integrated Risk and Performance - Part I
Liz Andrews 2700041WEU email@example.com | | Tags:  grc risk openpages | 0 Comments | 1,903 Visits
This is the first in a series of four blog posts where we will present risk and compliance speaker and thought leader, Michael Rasmussen's, GRC maturity model. For more insightful information on GRC and to exchange ideas with risk and finance colleagues, come see us in Orlando at Vision 2012.
Success in today's dynamic business environment requires organizations to integrate, build and support business processes with an enterprise view of governance, risk management and compliance (GRC). Without an integrated view of risk and compliance, the scattered and nonintegrated approaches of the past fail and expose the business to unanticipated risk.
In a mature GRC program, the organization has an integrated process, information and technology architecture that provides visibility across risk and compliance domains. It offers an integrated approach for business managers and executives to leverage GRC data for risk-aware decision-making and resource allocation.
Inevitable Failure: Managing GRC in Silos
The multifaceted risk environment
Risk to the business is like the hydra in mythology — organizations combat risk, only to find more risk springing up to threaten them. Executives are constantly reacting to risk appearing around them and fail to actively manage and understand the interrelationship of risk across the enterprise.
The dynamic and global nature of business is particularly challenging to risk management. As organizations expand operations and business relationships (e.g., vendors, supply chain, outsourcers, service providers, consultants and staffing) their risk profile grows exponentially. Organizations need to stay on top of their game by monitoring risk to their business internally (e.g., strategy, processes and internal controls) and externally (e.g., competitive, economic, political, legal and geographic environments) to stay competitive in today's market. What may seem an insignificant risk in one area can have profound impact on others.
Organizations are increasingly aware of the critical need to link risk management and corporate performance management. To manage corporate performance, the organizations must understand risk and make risk-informed business decisions.
In the area of regulatory risk, organizations face an expanding regulatory environment with rapidly increasing requirements that burden the business. Organizations face expanding regulations, increased fines and sanctions, and aggressive regulators and prosecutors around the world. Reputation and brand protection is also a significant compliance and risk management issue in a global environment.
Isolated risk and compliance initiatives introduce greater risk
Managing GRC activities in disconnected silos leads the organization to inevitable failure. Reactive, document-centric and manual processes for GRC fail to actively manage risk in the context of business strategy and performance, and leave the organization blind to intricate relationships of risk across the business. Siloed GRC initiatives never see the big picture and fail to put GRC in the context of business strategy, objectives and performance, resulting in complexity, redundancy and failure. The organization is not thinking about how GRC processes and controls can be designed to meet a range of risk and compliance needs. An ad hoc approach to GRC results in poor visibility across the organization and its control environment, because there is no framework or architecture for managing risk and compliance as an integrated part of business. When the organization approaches risk in scattered silos that do not collaborate with each other, there is no possibility to be intelligent about risk and understand its impact on the organization.
A nonintegrated approach to GRC impacts business performance and how it is managed and executed, resulting in:
The pain organizations have expressed
Siloed GRC processes, though effective in their own silos, are ineffective at an aggregate level, as the organization does not have a complete view of GRC in the context of the business. Corporate Integrity finds organizations that lack a collaborative, integrated and enterprise approach to GRC have:
Continue on to Part II in this series: GRC Maturity — Measuring a New Paradigm for Risk and Compliance
GRC Maturity: From Disorganized to Integrated Risk and Performance - Part II
Liz Andrews 2700041WEU email@example.com | | Tags:  openpages grc risk | 0 Comments | 1,870 Visits
This is the second in a series of four blog posts where we present risk and compliance speaker and thought leader, Michael Rasmussen's, GRC maturity model. For more insightful information on GRC and to exchange ideas with risk and finance colleagues, come see us in Orlando at Vision 2012.
GRC Maturity — Measuring a New Paradigm for Risk and Compliance
Lacking an integrated view of GRC results in business processes, partners, employees and systems that behave like leaves blowing in the wind. Modern business requires a new paradigm for tackling risk and compliance issues across the enterprise. No longer can organizations afford to focus on single risk and compliance issues as unrelated projects; nor can they allow software Band-Aids that are not integrated with the business to masquerade as GRC. A targeted strategy addressing GRC through common processes, information and technology gets to the root of the problem.
With changing and diverse risks bearing down on the organization, there is a clear need to tackle the problem at its root and develop a mature approach to GRC. Instead of treating each risk and compliance issue as an individual problem, organizations need to define a common process, information and technology architecture to manage GRC across the range of issues.
To address these issues, leading organizations have adopted a common framework, information architecture and shared processes to effectively manage risk and compliance, enable risk-aware decision-making, increase efficiencies, and be agile in response to the needs of a dynamic business environment.
The questions organizations must ask:
A well-defined GRC environment will not only do risk assessment and modeling, but will also deliver definition, communication and training on risk-taking and accountability. The organization must map the interrelationship of risks to controls, policies, enterprise assets (e.g., business process, employees, relationships, physical assets and logical assets), and incidents to business strategy, objectives and corporate performance.
Mature GRC delivers better business outcomes because of stronger integrated information, which will:
Architect integrated GRC systems and processes
A properly defined GRC architecture is built upon common process, information and technology components that are adaptive to a dynamic business environment and integrate with critical enterprise applications. No longer is risk and compliance about an annual audit; it now involves continuous monitoring in an ever-changing environment. GRC has to be sustainable as an ongoing and integrated part of business processes. A successful and mature GRC strategy has a symbiotic influence on the variety of business stakeholder roles and their common requirements.
Organizations need to be intelligent about what processes and technologies they deploy. The goal is to make an effective decision once, and comply with many regulations, manage a range of risks and maximize value from the convergence of technology, people and process. A sustainable approach to GRC results in an organization looking to the future and mitigating risk in the course of business, as opposed to putting out fires by reacting to risk and control issues as they arise.
Mature GRC enables the organization to understand performance in the context of risk and compliance. It achieves the definition of GRC, which is "a capability that enables an organization to reliably achieve objectives [GOVERNANCE] while addressing uncertainty [RISK MANAGEMENT] and acting with integrity [COMPLIANCE]." Effective and mature GRC delivers:
Continue on to Part III in this series: Five Stages of GRC Maturity
GRC Maturity: From Disorganized to Integrated Risk and Performance - Part III
Liz Andrews 2700041WEU firstname.lastname@example.com | | Tags:  risk openpages grc | 0 Comments | 1,862 Visits
This is the third in a series of four blog posts where we will present risk and compliance speaker and thought leader, Michael Rasmussen's, GRC maturity model. For more insightful information on GRC and to exchange ideas with risk and finance colleagues, come see us in Orlando at Vision 2012.
Five Stages of GRC Maturity
Mature GRC is a seamless part of governance and operations. It requires the organization to take a top-down view of risk, led by the executives and the board, and made part of the fabric of business, not an unattached layer of oversight. It also involves bottom-up participation where business functions at all levels identify and monitor uncertainty and the impact of risk.
Corporate Integrity has developed the GRC Maturity Model to articulate an organization's maturity in GRC processes.
1: Ad Hoc/Unaware — Department-Level Maturity
Characteristics of this GRC stage are:
Organizations in the Ad Hoc/Unaware GRC stage answer many of the following questions affirmatively:
2: Fragmented — Department Level Maturity
Characteristics of the Fragmented GRC stage are:
Organizations in the Integrated GRC stage answer many of the following questions affirmatively:
3: Integrated — Department Level Maturity
Characteristics of the Integrated GRC stage are:
Organizations in the Integrated GRC stage answer many of the following questions affirmatively:
4: Aligned — Enterprise GRC Maturity
Characteristics of the Aligned GRC stage are:
Organizations in the Aligned GRC stage answer many of the following questions affirmatively:
5: Optimized — Enterprise GRC Maturity
Characteristics of the Optimized GRC stage are:
Organizations in the Optimized GRC stage answer many of the following questions affirmatively:
Come back next week to view the final post in this series: Getting to the Head of the Class: Advancing Your Organizations GRC Maturity
Convergence of Risk Management and Performance Mangement
Erwin Boeren 270002C43V email@example.com | | Tags:  analytics grc busness management openpages ibm erwin boeren performance risk | 0 Comments | 1,777 Visits
Last year IBM acquired OpenPages as a strategic move into the area of Governance, Risk and Compliance. The lasest announcement to acquire Algorithmics (quantitative risk management) shows the continuous commitment of IBM in the GRC market. GRC software will integrate into the Business Analytics Software group, the area where the former acquisitions like Cognos, SPSS and Clarity systems already resides.
Now that Risk Management is evolving, more and more organizations are starting an enterprise approach to risk management. And this is where I see the need for Risk and Performance Management convergence.
In past Risk Management implementations I see that a major portion of time and budget was spent on Risk Reporting and Dashboarding. Especially the need for self service reporting, where users can ad hoc create their own risk reports, is growing. We do not want to wait in the queue waiting for our report to be created. 2 days later you missed the opportunity to respond and the loss is there.
With this self service capability the question automatically pops up 'can I trust my data'. And now we are back in the area of data governance. This is exactly where the area of Performance Management is today.
Apart from these reporting and dashboarding capabilities Enterprise Risk Management means alignment of risks and controls to the strategic initiatives of the organization. What will prevent me from reaching my business goals? Isn't this defined as a risk? And how will we prevent this from happening? Wasn't that defined as a control?
Even more interesting are questions like, 'What if I was able to perform risk scenario planning?', 'What if I could predict risks from happening?' or 'What is the correlation between the risks that have materialized?'.
And there is the proof that Risk Management and Performance Management have lots in common and should be integrated. Lets call it Business Analytics.
Erwin Boeren
Governance, Risk & Compliance Leader
IBM IOT Southwest Europe
Governance. Risk and compliance on the iPad
Erwin Boeren 270002C43V firstname.lastname@example.com | | Tags:  openpages grc ipad solvency reporting | 0 Comments | 1,672 Visits
With Cognos 10.1.1 released you must have noticed the ability of having your reports and dashboards on mobile devices like iPad and iPhone.
With these mobile capabilities CROs (Chief Risk Officers) will now have the ability to measure risk from their mobile devices. For volatile risk areas like Market and Credit Risk this can make a huge difference.
IBM developed a risk monitoring system for CROs where one single version of the truth is provided of different risk areas like Credit Risk, Market Risk, Counterparty Credit Risk, Liquidity Risk, Basel II, Solvency II and Operational Risk. Not only does a CRO have the ability to monitor all these risk areas but he can also monitor the correlation between those risk areas and he is able to respond immediately to changes. Responses can immediately be formulated in the integrated social media platform.
One version of the truth and guaranteed quality of your data is simple to say but how do you govern this? This is where IBMs investment in data models starts to pay off. Since decades IBM develops and maintains data models for financial services including out of the box technical and business definitions. This enables organizations to come to one definition of risk over the entire organization. Taking definitions centrally will add value in the process of taking down the silod approach we spoke about in earlier articles. It will also help you in the accountability process of the business. Finally it is the business that should own the business definitions.
As discussed in our previous published blog (The convergence of GRC and Performance Management) Business Analytics capabilities like risk forecasting, risk adjusted profitability calculations, scenario planning and predictive risk analysis are part of this risk monitoring system called FIRM (Finance Integrated Risk Management).
The new regulation for Insurance companies, Solvency II requires organizations to plan their risk assessments and capital requirements 2 to 5 years ahead and to reflect impact on financial positions when a risk materializes. All this means that an integrated approach to risk management is a must. In next blogs we will go deeper into the Solvency II regulation.
IBM Business Analytics interview with former SEC Chairman Christopher Cox
Liz Andrews 2700041WEU firstname.lastname@example.com | | Tags:  openpages regulatory_compliance dodd-frank sec | 0 Comments | 1,656 Visits
The following excerpts are taken from "Compliance, complexity and the need for XBRL: An interview with former SEC Chairman Christopher Cox":
What are the key drivers of regulatory reform? Will Dodd-Frank really reduce systemic risk? Can better compliance processes drive better financial results?
In the weeks running up to the Vision 2011 and OPUS 2011 conferences, experts within IBM Business Analytics Financial Performance and Strategy Management posed these and other questions to Christopher Cox, a former SEC Chairman and keynote speaker at both events. Below is a transcript of that interview.
Looking forward into the next three years, what are some of the key drivers in the US that will be shaping regulatory and compliance reform? How are those different from the past five years?
The most significant characteristic of the time we are living in right now is the remarkable pace of change, both in legislation and in regulations governing corporate America, in particular the financial services sector.
Of course, the Dodd-Frank 2,300-page behemoth is well-known already to senior finance executives. But what is unknowable are the hundreds of rules that will be forthcoming under that legislation. The schedule called for in the statute has the bulk of the final rule makings scheduled for completion in the third quarter of 2011. It is very clear across the regulatory agencies that these deadlines are going to be largely missed.
As a result, not only will there be regulatory uncertainty on a continuing basis this year, but also for several years into the future. There are over 100 rule makings that have no statutory deadline at all. I think a significant share of even those that were expected to be completed earlier will also be rolled into the future. So during all of this time, senior Finance executives are going to have to be reading the tea leaves – not to mention the statute itself – to determine how to comply. And it isn't just Dodd-Frank, of course, where we have all this legislative and regulatory ferment. The unprecedented rapid pace of chance in law and regulation and the continued uncertainty about what the government will do next pertains to the tax area as well. During the last year alone, Congress enacted no fewer than six major pieces of tax legislation – including the two "Obamacare" bills, the HIRE Act, the Education Jobs Act, the Small Business Jobs Act and, of course the year-end Tax Relief Act that temporarily extended the current tax rates.
That last piece of legislation bought us at least two years of tax certainty, but when it comes to long-term capital gains or any of the other rules governing the taxation of investment, two years are scarcely enough to permit long-term planning, and so the uncertainty continues.
That uncertainty about where financial, tax and regulatory policy are headed in turn creates a challenging environment within companies and within firms when it comes to shaping their response to regulatory and compliance changes. That's the environment in which we find ourselves. Given the extent of this change and the predictable uncertainty that will continue for several years, it is very important that companies respond to this in ways that are exceptionally flexible.
How should Finance organizations prepare for this future regulatory environment in spite of uncertainties, particularly global companies that do business in multiple jurisdictions? What sustainable practices in their control and reporting processes and systems do they need to invest in to prepare for the future?
Being globally active, of course, only ramps up the uncertainty because the requirements from multiple jurisdictions are layered on the responsibility of senior Finance executives for U.S. compliance. It is nonetheless possible to synthesize thematically many of the global requirements, because at least topically, they have very much in common.
What is most important is that the different parts of a global organization can talk to one another and that the human beings who must extract information from the IT systems that collect and disgorge that information can rationalize it. In particular, companies that address these changes in ways that are adaptable and flexible will have a clear advantage. Companies that fail to manage the process in this way will likely find their companies non-compliant and their risk management practices called into question – not only by regulators, but also by their shareholders and their customers.
Do you think that the passage of Dodd-Frank will reduce systemic risk and improve stability in our financial services institutions?
Unfortunately, the Dodd-Frank Act failed to address several of the
most significant causes of instability in the financial system and
sources of systemic risk. The first is the status of the
This is particularly salient, as the conservatorships have required the GSEs to engage in practices that support housing at the expense of their financial well-being. Likewise, the government's completely unjustifiable practice of keeping these two GSEs off the federal balance sheet, even as they are under government ownership, makes a mockery of financial reporting norms and honest accounting. Addressing this glaring omission in the Dodd-Frank Act remains a top priority of financial reform.
Next in importance is the inadequacy of bank capital and liquidity standards. Dodd-Frank did not adequately address the obvious failure of the Basel standards in the financial crisis. Those standards continue to create powerful incentives for asset concentration in mortgages and a reliance on credit ratings, and of course both of those had a role in generating the mortgage bubble that led to the financial crisis.
So the short answer to that question would be "No."
Correct. I'd also say that Dodd-Frank has given the Financial Stability Oversight Council a strong incentive to protect competitors rather than to protect competition, which might take market share from the dominant firms. The systemically important designation implies government readiness to support those firms in a crisis, perversely encouraging more risky behavior despite the more stringent capital and other requirements and thus deepening moral hazard.
Can you discuss some of the best practices for boards of directors with regard to risk oversight? Do you think that changes in proxy disclosure with regard to risk governance has had an impact on risk management practices?
Yes. In 2010, the SEC added requirements for proxy statement discussion of a company's board leadership structure and its role in risk oversight. Now companies are required to disclose in their annual reports the extent of the board's role in risk oversight, and they're required to address such topics as how the board administers its oversight function, the effect that risk oversight has on the board's processes, and whether and how the board or one of its committees monitors risk. That increased focus on risk management has had considerable and very earnest take-up across the corporate community.
There are several types of actions that companies and their appropriate committees have been taking to step up their focus on risk management. Without question, they are spending more time with management, and isolating the categories of risk that the company faces – focusing on risk concentrations and interrelationships, the likelihood that these risks might materialize, and the effectiveness of the company's potential mitigating measures.
Many companies have created risk management committees. Financial companies, of course, that are covered by Dodd-Frank must have designated risk management committees, but boards of other companies have carefully considered the appropriateness of a dedicated risk committee, and many of them have found it prudent to create one. In other cases, boards have delegated oversight of risk management to the audit committee, which is consistent with the New York Stock Exchange rule that requires the audit committee to discuss policies with respect to risk assessment and risk management.
For large-cap companies that have a Big Board listing, that has continued to be another way to address these heightened concerns. I think boards are carefully bearing in mind that different kinds of risks may be better-suited to the expertise of different kinds of committees, so they may not always wish to stovepipe responsibility for risk in a single committee.
Above all, best practices today are focused on the fact that regardless of how the board subdivides its responsibilities, the full board has the responsibility to satisfy itself that the activities of its various committees are co-ordinated and that the company has adequate risk management processes in place.
It's a fascinating world. I can see why if you're a controller or CFO it's an exciting but intense place to be.
I think that's absolutely right. All of these changes we've discussed – in particular in the US – mean that we are entering an era of unprecedented demand on companies' governance, risk, and compliance processes and IT infrastructures. I think that companies have dealt with regulatory changes over the past half-century largely incrementally. They've made adjustments to their enterprise-wide systems as needed to comply with what have been modest changes from year to year. But given the enormous scope of changes in these forthcoming new regulations, companies will find it necessary to find a comprehensive and holistic approach to at least regulatory reporting – and, in my view, their management control as well.
Companies have traditionally relied on different processes to gather enterprise data to help management run the business on the one hand, and to gather data in order to satisfy regulators, on the other. In part, that was sustainable because the information that regulators were requiring was historical and post-facto. But things are rapidly changing under these new frameworks. Regulators including the SEC are now requiring information that is risk-based and predictive. While that is a big change, it's also a significant silver lining in that this will align the process of collecting and gathering information more closely with what management needs. That means that CIOs should be looking for ways to integrate their regulatory and their management reporting processes. For that reason, regulatory reporting doesn't have to be viewed as sheer cost, or necessary evil. Instead, there can be significant efficiencies and productivity gains for the enterprise by merging the requirements of management and regulatory data gathering processes.
This convergence will also allow companies to restructure their data in a way that will feed predictive analytical systems. That, in turn, can lead to an improvement in both risk management at the board level, and risk-based decision-making processes at the management level.
About Christopher Cox, Former Chairman, United States Securities and Exchange Commission (SEC)
Beginning in 1988, when he was elected to the House of Representatives, Christopher Cox established a record of legislative accomplishments that elevated him to the top of the Congressional leadership. His wide range of expertise in a variety of complex issues gives him the ability to take the long view of the economic future, predicting both the actions of Congress and the effects those actions will have on the marketplace. The author of the Internet Tax Freedom Act, which protects Internet users from multiple and discriminatory taxation, Cox held leadership positions ranging from chairmanships on committees and taskforces overseeing everything from budget process reform and policy to homeland security and financial services. During his tenure as chairman of the Securities and Exchange Commission, he continued this fight for justice and transparency in the world of investing.
An Accomplished Lawmaker and Reformer. During his seventeen years in Congress, Cox served in the majority leadership of the U.S. House of Representatives. He authored the Private Securities Litigation Reform Act, which protects investors from fraudulent lawsuits, and his legislative efforts to eliminate the double tax on shareholder dividends led to legislation that cut the double tax by more than half. In addition, he served in a leadership capacity as a senior member of every committee with jurisdiction over investor protection and U.S. capital markets, including the Energy and Commerce Committee, the Financial Services Committee, the JointEconomic Committee, and the Budget Committee.
An Advocate for Investors. At the SEC, Cox focused on the enforcement of securities law enforcement, bringing a variety of groundbreaking cases against market abuses such as hedge fund insider-trading, stock options backdating, and municipal securities fraud. He also helped turn the Internet into a secure environment, free of securities scams, and he worked to halt fraud aimed at senior citizens. As SEC chairman, he was one of the world's leaders in the effort to integrate U.S. and overseas regulatory policies in this era of global capital markets, making international securities exchanges safe, profitable, and transparent. As part of an overall focus on the needs of individual investors, Cox reinvigorated the SEC's initiative to provide important investor information in plain English, championing the investor's right to a transparency. His reforms included transforming the SEC's system of mandated disclosure from a static, form-based approach to one that taps the power of interactive data to give investors qualitatively better information about companies, mutual funds, and investments of all kinds.
In 1994 Cox was appointed by President Clinton to the bipartisan commission on entitlement and tax reform, which published its unanimous report in 1995. From 1986 until 1988, he served in as senior associate counsel to President Reagan. From 1978-1986, he specialized in venture capital and corporate finance with Latham & Watkins. Cox received an M.B.A. from Harvard Business School and a J.D. from Harvard Law School, where he was an Editor of the Harvard Law Review.
Whistleblowing Worries On the Rise
Richard Steinberg 270004HRBG firstname.lastname@example.com | | Tags:  openpages risk dodd-frank grc whistleblowing sec | 0 Comments | 1,466 Visits
The SEC's final rules implementing Dodd-Frank's whistle blowing provisions failed to remove angst among compliance officers and general counsels. While there are some incentives for potential whistleblowers to first report alleged misconduct via internal reporting channels, there's no requirement to do so – and many are concerned the internal channels will be bypassed. And going outside is on the rise. It's been reported that in only seven weeks after the SEC's program began, there were 334 whistleblower filings. Compliance officer concerns are well founded – that bypassing internal channels will deprive the company of being able to investigate and fix problems before they grow, and company personnel will need to play catch up with investigations in reaction to SEC probes.
We can point to many resolved whistle blowing cases for clear evidence of the potential impact of the SEC's still relatively new program. One homeowner delinquent on her mortgage ultimately received $18 million for reporting suspected use of fraudulent documents in the bank's foreclosure process. It's said that in acting against this homeowner – an attorney and career insurance fraud investigator – the bank "picked the wrong person at the wrong time in the wrong place," but the robo-signing and other compliance failures were widespread and surfaced from a number of sources. Nonetheless, this individual was one of six whistleblowers receiving $46.5 million said to be part of the five-bank $25 billion settlement. In an unrelated case, a member of a major bank's quality control team who reportedly was displeased that the misconduct wasn't reported to regulators, decided to do so herself – ending up with a settlement of $31 million. And there are many more.
Worth noting is a recent survey that indicates more than one-third of American workers have seen misconduct on the job. While many instances of misconduct have been reported through internal channels, it appears the vast majority have not. Why? The survey shows it's because of fear of not being able to remain anonymous, and of retaliation. Those two factors, plus the possibility of monetary reward, are reported as key factors in incentivizing internal reporting. And the survey also shows two-thirds of respondents didn't know about the SEC's program – at least not yet.
Certainly it's in a company's interest to be first to know about alleged misconduct, and compliance officers are working hard to upgrade policies, training, communications, and the internal whistleblower systems, all to encourage internal reporting. Actions to ensure anonymity, with positive responses and nothing close to retaliation, are expected to help. Some companies have begun to pay bounties for valued reports. There are indications that when employees believe their reports will be taken seriously without adverse repercussions, there's increased likelihood for internal reporting. Law firms and others have provided guidance on which companies are acting. However, it remains to be seen the extent to which the possibility of a huge, life-changing payday by the SEC will be too much to resist. Time will tell.
The Fed's New Proposed Rules on Risk Management
Richard Steinberg 270004HRBG firstname.lastname@example.com | | Tags:  dodd-frank risk risk_management openpages | 0 Comments | 1,244 Visits
If you're in or work with the financial services industry, you probably know about the late December holiday "gift" from the U.S. Federal Reserve – proposed rules implementing provisions of the Dodd-Frank Act which could have a profound effect on how boards and managements deal with risk. In any event, you'll want to keep in mind that the Fed is accepting comments only for the next month – until March 31.
The proposed rules are far-reaching, including requirements for risk-based capital and leverage, liquidity, stress tests, sing
The risk committee is required to "document and oversee, on an enterprise-wide basis, the risk-management practices of the company's worldwide operations." The committee would be chaired by an independent director, and at least one member needs to have risk-management expertise commensurate with the company's size, complexity, and other risk-related factors. Further, its members are expected to understand risk-management principles and practices relevant to the company, with specified experience in risk management. And there are rules for a committee charter, meetings, and documentation.
The committee's responsibilities include reviewing and approving an appropriate risk-management framework commensurate with the company's size and other factors. The framework's scope is outlined, including requirements for risk limits appropriate to each line of business, policies and procedures for risk-management practices, processes for identifying and reporting risks, monitoring compliance with risk limits and procedures, and specification of management's authority and independence to carry out risk-management responsibilities. Additionally, the larger covered companies will need to appoint a chief risk officer in charge of implementing and maintaining the risk-management framework and practices approved by the risk committee, with the rules specifying responsibilities and qualifications for the CRO and reporting relationships.
If not already under way, now is the time to analyze the proposal and its implication, and let the Fed know what changes are needed. If interested, you might want to tune into the upcoming IBM OpenPages webinar where I'll be discussing the proposed rules, their implications and the challenges they present – March 8, 2:00 pm Eastern Time.


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subset: commoncrawl


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National statistics report that it takes an average of six months for new graduates to find a job. Our career counselors are available to help job seekers develop a plan and follow through with that plan. Call (616) 526-6485 or stop by to schedule an appointment.
Most job openings are never posted, so networking is one of the most effective means of finding employment and tapping into the "hidden" job market. For more information on networking, review our handout
uKnight offers an online networking directory for Calvin students (once they complete their freshman year) and alumni. Use uKnight to contact Calvin alumni who have agreed to share their professional and career-related advice.
is a popular professional networking site. Start your account today to connect with hundreds of professionals in your field! Connect with Calvin alumni by joining the Calvin College Alumni & Friends group. This resource for students provides tips for making your LinkedIn profile stand out and using LinkedIn as a tool in your job search.
Develop your social networking campaign with the help of a carer counselor. Contact us to schedule an appointment.
Job fairs are a great place to network with employers. Company representatives attend job fairs to meet potential employees and increase awareness of their organization.
Review our handout for information about job fairs.
Online research should be one aspect of job searching, not your entire job search strategy. This method of conducting a job search is not meant to replace face-to-face networking or a trip to our office.
Before you post your resume online, ask yourself a few questions such as privacy protection and the length of time your resume will remain in the service provider's database. Consider removing personal information, like your address, from your resume, and using an email address that you set up for job-related activities only. Be very cautious when sharing personal information over the internet, to employers and to job search sites.
Note: The links below to non-Calvin sites do not constitute an endorsement.
General Links
Get the Symplicity (CalvinLink) app*
ArtCreative Hotlist
New York Foundation for the Arts
BusinessCPA Career Center
One Wire
Society for Human Resource Management
American Marketing Association Job Board
Communications and MediaJournalism Jobs
Media Bistro
Public Relations Society of America Job Center
Staff Me Up (media production jobs)
EngineeringAmerican Society of Civil Engineers
American Society of Mechanical Engineers
Institute of Electrical and Electronics Engineers
American Institute of Chemical Engineers
EnvironmentalStudent Conservation Association
Green Jobs
Renewable Energy Jobs
Sustainable Business
GovernmentState of Michigan
USA Jobs - Federal Jobs
HealthHealth Career Web
InternationalEntravos (entry-level international development jobs)
Glassdoor - Information about multiple countries
My Visa Jobs: Home Page
My Visa Jobs: Top visa sponsors, recent work visa petitions and new openings near Grand Rapids
Jobs Within MichiganMI Talent
Intern in Michigan
Career Matrix
Math and ScienceBioSpace
Chemistry Jobs
Math Classifieds
New Scientist Jobs
Physics Career Center
Society for Industrial and Applied Mathematics
Non-Profit/Social ServicesIdealist.org
Public Service Careers
Social Work Career Center
Sports and RecreationNational Recreation and Park Association Career Center
Teamwork Online
Technical/Information TechnologyDice.com
Computerworld IT Jobs
TeachingASCI (Association of Christian Schools International)
Christian School Employment
Chritian Schools International
Council of International Schools
K-12 Job Spot
Southern Teachers Agency
Teach Away
Top School Jobs
Writing and PublishingBook Jobs
Publishers Weekly Job Zone


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Hi Guys,
Just jailbreaked my PS3 today. It's been a HUGE learning curve for someone not very Techy... in fact it took me around 15 hours to Jailbreak my PS3 with a E3 stick... which should only take 20 minutes
In the jailbreak list it shows Little Big Planet and Heavy Rain as being able to play from external/Internal.
Well when i select either game with Gaia, Open Manager or BackUp Manager... it just brings me back to the XMB over and over.
The game itself doesn't load up.
I have Turok, Resistance 2, Heavy Rain, and LBP on my external Drive... Turok, and Resistance load up fine. What am i doing wrong?
Again i open Gaia - select Little Big Planet - I Select the game and press "X" - it brings me back to the XMB - then i go to the *app_home/PS3_GAME which will then turn into the Little Big Planet Icon - i press "X" again to launch the game... but it brings me back to the XMB over and over. I've tried it from my internal and external.
I know most of you have likely seen these types of post a hundred times, but really wanted to say thanks in advance for helping me.
I'm not too clear on the terminology, and just want to learn.


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About the Catalog
The University Catalog is the official university document that provides comprehensive information regarding degree programs and their requirements, courses, academic policies and special programs. Some fee and financial aid information can be found as well.
Rights and exclusions regarding specific degree requirements pertaining to this Catalog have been established for undergraduate students. For more information regarding this policy, please visit Catalog Rights and Exclusions in the Requirements to Graduate section.
All of the information regarding academic policies, degree programs and courses have been approved by the Educational Policies Council. The membership of the council includes the provost, college deans, and representatives from the Faculty Senate and each college. Meetings are held nine times per year and are open to interested parties.
While every effort is made to provide accurate and current information, Kent State University reserves the right to change without notice statements in the University Catalog concerning rules, policies, fees, curricula courses or other matters.
Kent State University Seal
IMAGE: Seal
The Official Seal of Kent State University is located on the homepage. The seal denotes that the online University Catalog is the official university document of record with regard to academic programs and policies. The Kent State University Seal is a registered trademark and may not be used without permission.
Course Information
Course descriptions include a synopsis of the content to be covered in the course, the course prerequisite, if the course fulfills a university requirement, applicable fees, if the course if cross-listed with another department and if the course is repeatable. The course descriptions are divided into fall and spring semesters, with each course appearing in both semester listings. Please note that there may be differences in the same course from one semester to the next. Some courses require that a fee be paid in addition to instructional and general fees. These special fees, listed with the the course description for each appropriate course, are subject to change at any time, upon approval by the Board of Trustees.
Most courses are offered in a regular sequence to meet students' programmatic needs; however, the availability of any specific course in a given semester is subject to sufficient student demand and available resources. Please check the Schedule of Classes for specific semester availability.
Students who do not meet the course prerequisites may appeal to the department for approval to register.
Previous Years' Course Descriptions
Course descriptions for academic years 1998 to 2009 can be found online in the catalog archives. For course syllabi, please contact the instructor or academic unit for copies.
To order pre-1998 course descriptions
Please contact the Office of the University Registrar at 330-672-3131 or online at www.registrars.kent.edu.
Printed Catalog
The University Catalog is available online only.
Contact Information
The University Catalog is produced and maintained in the Office of Curriculum Services under the auspices of the Office of the Provost and Senior Vice President for Academic Affairs.
Please e-mail or visit us online if you have any questions regarding the University Catalog or the curriculum process.
E-mail: email@example.com
Web: www.kent.edu/provost/curriculum


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|Relay For Life to celebrate 'Decades of Hope' Friday
|Written by Holyoke Enterprise
Phillips County will host its 12th annual Relay For Life event Friday-Saturday, June 7-8 at the Haxtun baseball field to raise money for the American Cancer Society.
During the night, relay team members and cancer survivors will honor those who have lost the fight to the disease as well as celebrate those who have emerged victorious in their battle with cancer by completing hundreds of laps around the track.
Jeff Plumb, Rod Workman and Star 92.3 will handle emcee responsibilities for the event.
The evening will get started with a welcome from event chair Abby Henry. The opening ceremony will begin at 6 p.m. with the theme being "Decades of Hope."
Teams will dress and decorate their campsites in accordance with the decade their team represents.
Kelli Lightsey of Haxtun will share her story of fighting cancer at 6:15 p.m. Lightsey battled breast cancer and has been in remission for four months.
A survivors lap is scheduled for 6:30 p.m. Cancer survivors will take the first lap around the track to celebrate overcoming cancer while also acting as inspiration for those currently afflicted with the illness.
A dinner will be provided by The Dutch Oven of Haxtun and R&B Catering of Holyoke at 7 p.m. While the dinner is open to the public, those who are not cancer survivors or on a team are encouraged to make a donation.
The luminaria will be lit with a ceremony planned to begin at 9 p.m. From 9-10 p.m. participants will partake in silent laps to remember those who have lost the battle with cancer, to support those still fighting and to honor those who have faced cancer in the past.
Luminaria can be purchased next to the stage at the baseball field.
Several activities and games will also be offered throughout the night including "Minute to Win It" games, Wii hour on a blow-up television screen, Mr. Relay and a Relay Idol contest.
A best food of the decade competition will also take place from 7-11:30 p.m. Keeping in line with the theme, teams will enter a dish that best represents their decade. Donation jars will be placed by each entry and the winner will be the one who receives the most money.
Drawings for a number of prizes will also be available to those who camp out throughout the night.
During the Wednesday, May 29 Bank Night, $19,000 was collected from participating teams. There are currently 18 teams and 205 people already registered for the event.
Money for Relay For Life will be collected until midnight.
The event will come to an end with the closing ceremony at 7 a.m.
During the 2012 Relay For Life, Phillips County raised nearly $30,000 with proceeds going toward cancer research.
Those who have yet to sign up to participate can do so up until the start of the event.
To sign up, purchase luminaria before the event or for questions regarding volunteering or sponsorship for Relay, contact Abby Henry at 970-580-8980 or visit phillipscountyrelay.org.
Holyoke Enterprise June 6, 2013