Page 34 - CCB_Annual Report_2022
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34   Strategic Report                                                                                                                                                                                                             35












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