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059

Case 059Operational risk and loss eventsHard

A bank discovers that a trader hid losses that grew from Rs 50 crore to Rs 900 crore over eighteen months using fictitious offsetting trades, while reporting steady profits. From the incident file, identify the control failures, show how the loss grew and present what should change.

SCSchrodersNew York · 2020

1The situation

Ostrova Bank's internal audit has handed you the incident file. A trader on the equity derivatives desk, who had spent four years in the bank's back office before moving to trading, ran a book described as a hedged arbitrage strategy. He took large one-way positions and booked fictitious trades that appeared to offset them, so the book looked flat.

His hidden losses were about Rs 50 crore by month 6, Rs 300 crore by month 12 and Rs 900 crore by month 18. Throughout, he reported a steady profit of about Rs 4 crore a month. He never took more than two days of leave. The fraud surfaced when a counterparty queried a trade it had no record of.

2Your task

Identify the control failures, show how the loss grew and why, and present what Ostrova should change, as you would to a risk committee after thirty minutes with the file.

Quick check

Which single signal in the file should have worried the bank earliest?

Worked solution

Try it on paper, then open one step at a time.

30-second answerThe answer to give first

Five controls failed in sequence: unconfirmed trades were not chased, leave was never enforced, funding needs were not reconciled to a flat book, profits too smooth for a hedged strategy were not questioned, and a former back office employee kept the knowledge to defeat the checks. The loss grew about 27% a month as the trader doubled up to recover, so each month of delay cost more than the last. Catching it at month 6 would have cost Rs 50 crore, not Rs 900 crore.

Step 1How did the loss grow, and why so fast?

Think of a gambler who hides a loss from his family and then bets bigger to win it back before anyone notices. Hidden losses grow faster than open ones because the person hiding them has every reason to take more risk to close the hole. Ostrova's losses went from Rs 50 crore to Rs 300 crore in six months, six times, then to Rs 900 crore in the next six. Across the year from month 6 to month 18 that is about 27% a month. In the last six months the hole grew by about Rs 100 crore a month, while the trader reported Rs 4 crore a month of profit.

What Ostrova saw against what was true, cumulative Rs crore0-300-600-900+72-828reported: steady +4 a monthtrue: hidden losses compound12345month 0month 6month 12month 18Numbered squares: control points that could have caught it (see the next figure)
Ostrova saw cumulative profit rise steadily to Rs 72 crore over eighteen months while the true result, after hidden losses, fell to about minus Rs 828 crore, with five control points along the way where the gap could have been caught.
Step 2Which controls failed, and in what order?

Walk the file in time order, because the committee will ask when the bank could first have known. No single control had to be perfect; any one of five working normally would have caught the fraud while the loss was a fraction of Rs 900 crore. The fictitious trades had no counterparty, so they could never be confirmed, and unconfirmed trades should age into escalation within days. The trader never took block leave, which is exactly the control designed to let someone else run a book for two weeks and find what does not reconcile. His real positions needed margin and funding that a flat book should not need. His profits were too smooth for the strategy. And his segregation of dutiesSplitting a process so that no one person can both carry out and check the same transaction. was weakened by what he knew from the back office about how bookings were checked.

Five controls, five chances: what failed and what should changeControlWhat was missedWhat should change1Month 2Trade confirmationsOffsetting trades never confirmedby any counterpartyChase every unconfirmed trade;escalate by age2Month 5Mandatory leaveTrader never took atwo-week breakBlock leave with positions runby someone else3Month 9Cash and marginReal positions needed funding aflat book should notReconcile funding and marginto reported risk4Month 12P&L reasonablenessA hedged book earning steadilywith almost no volatilityFlag returns too smooth forthe stated strategy5Month 15Access and dutiesEx-back office trader knew howbookings were checkedRemove old access; review staffmoving to the desk
Five controls failed at Ostrova: trade confirmations, mandatory leave, reconciliation of funding and margin to reported risk, a reasonableness check on profits, and the access and knowledge a former back office employee carried to the desk; each had a specific fix.
Step 3What does the cost of delay look like?

Put the numbers against the control points. Caught at month 6 the loss is Rs 50 crore; at month 12, Rs 300 crore; at month 18, Rs 900 crore, so the same fraud costs eighteen times more for being found a year later. This is why operational risk cares about detection speed as much as prevention. A control that catches a fraud in weeks turns a capital event into an embarrassing loss; one that catches it in eighteen months turns it into a question about the bank's survival.

MonthReported cumulative profitHidden lossTrue cumulative result
0000
62450-26
1248300-252
1872900-828
Rs crore. Reported profit rose by Rs 4 crore a month while the hidden loss reached Rs 900 crore, so the true cumulative result at month 18 was about minus Rs 828 crore.
Step 4What would you present to the committee as the changes?

Group the fixes by what they protect. Detection: every unconfirmed trade chased and escalated by age, reconciliation of margin and funding to reported risk, and an alert on returns that are too smooth for the strategy the desk says it runs. Prevention: two weeks of block leave each year for every trader, with the book run by someone else, access rights removed when staff move from operations to the desk, and gross as well as net position limits, so a book that is large but looks flat is still visible. Culture: a steady earner should get more questions, not fewer. Close by saying which of these would have caught this case first, trade confirmations, because the committee will fund the fix it believes.

Where candidates lose it

The usual loss is listing controls as a checklist without the timeline. The committee wants to know when the bank could first have known and what that would have saved, so tie each failed control to a month and a loss figure.

The second is treating steady profits as good news. In a supposedly hedged book, smooth returns are the anomaly, and saying so is what separates a risk answer from an audit recital.

What the interviewer asks next

  • Only one of the five controls can be fixed this quarter. Which one, and why?
  • How would you size the operational risk capital impact of a loss like this?
  • What would you look for in the trader's cancel and amend history?
  • How do you stop the new controls becoming box ticking within two years?

Asked at Schroders, Risk Management, New York, 2020 (Wall Street Oasis): reading 20-something page in 30 minutes about a loss case at a bank with 2 cases to choose from

← Case 058A bank has 40 models: 8 complex capital and pricing models, 20 moderate scoring and reporting models and 12 simple tools. Tier them, set validation cycles and estimate the validation team's annual workload.Case 060 →A port company has a Rs 1,200 crore bullet loan at 8.5% maturing in two years and operating cash flow of Rs 180 crore. If refinancing costs 11%, what happens to its interest burden and cover, and what should the lender require now?

Company names and figures are illustrative.

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