The three lines of defence model for operational risk management needs constant fine-tuning if it is to work effectively for larger banks, practitioners have said. Regulators have sought to make the approach a banking industry standard, but the past 18 months have seen a string of risk managers complain it can be difficult to put into effect.
Initial attempts to implement the approach at HSBC “caused a lot of confusion”, according to Jenny Birdi, the bank’s global head of operational risk audit
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