
Explanation:
B is correct. An internal auditor or an independent model validation group should be responsible for model validation. Having the model developer actively participating in the model validating process is a conflict of interest.
A is incorrect. It is not a conflict of interest. The second line of defense is risk managers that specialize in risk management and day-to-day oversight, which falls under the supervision of the CRO.
C is incorrect. It is not a conflict of interest as these two responsibilities do not conflict with each other from the perspective of a senior economist at a regulatory agency, since it is part of the economist's job responsibility to help draft a proposal for a market reform. A stronger example of a conflict of interest would be, for example, a regulator that helped draft the reform joins a financial consulting firm and advises the industry on how to circumvent the safeguard.
D is incorrect. It is not a conflict of interest. Business unit heads may be compelled to issue an alert when an exposure reaches a certain threshold (e.g., 85% of the limit). The CRO, jointly with the unit head, could then petition the bank's business risk committee for a temporary limit increase. Upon approval, the business risk committee would then submit the request for final approval by the senior risk committee.
Learning Objective: Interpret the relationship between risk and reward and explain how conflicts of interest can impact risk management.
Reference: Global Association of Risk Professionals. Foundations of Risk Management. New York, NY: Pearson, 2023, Chapter 1, The Building Blocks of Risk Management [FRM-1].
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Q-68. A risk manager is reviewing the inherent deficiencies that are commonly observed in risk management frameworks and assessing how risk management systems can be compromised by human agency. The manager focuses on cases involving conflicts of interest, which undermine the credibility of a risk management system. Which of the following is the best example of a conflict of interest?
A
The CRO of a bank provides oversight over the second line of defense of the bank.
B
A model developer is given responsibility for validating the soundness of the model.
C
A senior economist at a regulatory agency helps draft a proposal for a market reform and also advises on trading regulation for the government.
D
The head of a business unit of a bank petitions to the risk committee for a temporary risk limit increase for that unit.