Page 35 - 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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