Page 34 - CCB_Full-Annual-Report-2021
P. 34

34     Strategic Report                                                                                                                                                                                                             35








                                                                                                                                                                                                                                          Contents
                                                                                                                                                                                                                                          Contents

             Principal Risk   Governance     Risk Appetite Statement   Key Mitigants           Comments                              Principal Risk   Governance    Risk Appetite Statement   Key Mitigants           Comments


             Credit          Credit Risk     The Bank has a moderate      ∞Regular modelling of   Credit Risk                        Legal,         Compliance      The Bank maintains a         ∞Provision of guidance   Ensuring        Strategic Report
                             Management      appetite for Credit Risk   funding requirements   is one of the                         Compliance &   Framework       low appetite for Legal,    in relation to business,   compliance
             The risk that   Framework       overall, maintaining       and interest rate      principal risks                       Regulatory                     Compliance and Regulatory   product, and change   with all
             counterparties                  conservative parameters,   risk analysis          that the Bank                                        Compliance      Risk. Whilst we recognise   management requests   applicable
             fail to meet the   Lending      including a maximum LTV and                       faces, given                          The risk       Monitoring      that operational errors can                       regulatory
             commitments     Protocols       a DSCR at a higher level than     ∞Compliance with   the nature of                      that non-      Framework       occur, we maintain zero      ∞Ensuring appropriate   requirements in
             into which they   Credit        PRA requirements, focusing   detailed Risk Appetite   its business.                     compliance     Risk            tolerance for reportable   registrations under the   a fast-changing
             have entered    Committee       on relationship management,   and Lending Protocol   The lending                        with laws or   Management      breaches of regulations,   Senior Management      landscape is
             in a timely                     including annual reviews.   parameters            portfolio                             regulations    Committee       regulatory policy breaches,   and Certification   a challenge
             manner.         Risk &                                       ∞Quarterly Stress Testing   is closely                     could give                     breaches of applicable laws,   Regime through     to which the
                             Compliance      We will maintain the Bank’s   of the loan portfolio  monitored                          rise to fines,   Risk &        late responses to regulatory   second line oversight  Bank devotes
                             Committee                                                                                               litigation,    Compliance
                                             lending distribution and                          via a suite                                          Committee       requests or gifts/hospitality     ∞Maintaining logs of   considerable   Corporate Governance Statement
                             Environmental,   product offering within     ∞Segregation of      of detailed                           sanctions,                     policy breaches. We strive to   internal compliance   resources,
                             Social &        parameters agreed by the   responsibility for     metrics,                              reputational                   ensure that we always remain   breaches, regulatory   and the
                             Governance      Board, diversified by sector   the management of   including                            damage or                      within the law and regulation.   breaches & conflicts   Compliance
                                                                        loans and a program
                             (ESG)           and UK region, with a minimal   of underwriting from   Concentration,                   financial loss.                Regulatory Changes (Horizon   of interest         Framework
                             Committee       appetite for ‘speculative’   business development   Breaches and                                                       Scanning) are logged,                             is continually
                                             lending. These ensure that we                     Exceptions,                                                          allocated, monitored, and     ∞Horizon scanning   under review
                             Model Risk                                 and sales              Asset Quality                                                                                   to ensure continued    to ensure that
                             Oversight       concentrate lending on areas     ∞Use of seasoned   and Treasury                                                       tracked ensuring additions   adherence to regulatory   it meets all
                             Committee       where we have experienced                                                                                              to or changes within       requirements &
                                             subject matter experts both   professionals with   Counterparty                                                        regulatory requirements    developments           requirements
                                             in the first and second line of   deep subject matter   Indicators, and                                                are proportionately applied.                      and is in line
                                             defence, with the necessary   expertise, experience,   via the use of                                                  All material breaches are     ∞Regular reviews of   with leading
                                             operational capacity,      and ongoing training   credit grading                                                       investigated and reported   training content &    industry
                                             systems, and infrastructure     ∞Quality Assurance   models. Stress                                                    to the Risk & Compliance   oversight of the training   practices.     Independent Auditor’s Report
                                             to effectively manage and   checks to ensure      testing is                                                           Committee in a timely      & development of
                                             monitor the loans through   adherence to policies   employed to                                                        manner, rule changes       staff to ensure up to
                                             their life cycle. We will operate   and procedures  ensure that                                                        are implemented within     date knowledge base
                                             within protocols, underwriting                    sufficient                                                           the applicable regulatory
                                             guidelines, exception limits     ∞ Use of the Credit   capital is                                                      timelines and staff operate
                                             and regulatory guidelines   Grading Models as part   maintained.                                                       within the Bank’s documented
                                             and manage the Early       of the approval process,                                                                    policies and controls
                                             Warning Report and Watch   refreshed monthly,     The Bank                                                             and, where applicable,
                                             List proactively to ensure   allowing the portfolio   continues to                                                     industry guidelines.
                                             that asset quality remains   to be monitored on   assess the
                                             satisfactory. We will not   an ongoing basis.     potential
                                             chase growth at the expense     ∞Conducting annual   impact of                                                                                                                               Financial Statements
                                             of credit and asset quality.   reviews to ensure   climate change
                                             Although we recognise that   monitoring throughout   and the
                                             through the full economic   the facility lifecycle  environmental
                                             cycle, some credit losses                         factors
                                             are inevitable, our robust     ∞Close monitoring   across its
                                             underwriting standards aim   of non-performing    loan portfolio
                                             to minimise them, with close   loans, including Early   as well as
                                             monitoring of risk appetite   Warning Report, Watch   undertaking
                                             on a monthly basis via the   List, Forbearance, and   appropriate
                                             comprehensive suite of KRIs.  management of arrears  stress testing.

                                                                          ∞Detailed provisioning                                                                                                                                          Notes to the Financial Statements
                                                                        requirements and
                                                                        procedures
   29   30   31   32   33   34   35   36   37   38   39