medium · FRM Part 2 Operational Risk

A business unit identifies 50 risks in its RCSA, all with 'Residual Scores' of 1 or 2 (Green). The total 'Expected Loss' (EL) for the unit is $5 m.

Why might a CRO still be concerned about the 'Aggregate' risk of this unit?

  1. The SMA capital formula will double the required capital for this unit no matter what the RCSA scores indicate.
  2. A $5 m Expected Loss figure is inherently too large for a business unit whose residual risks are all currently rated 'Green'.
  3. The unit is clearly 'under-reporting' its inherent risk exposure deliberately just to keep the residual scores looking green.
  4. RCSA often misses 'Interdependencies'; 50 small independent risks may be highly correlated in a systemic stress event.

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