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Singapore's financial regulator
has issued its long-awaited consultation on the management of outsourcing
risk. Issued as a consultation paper, the guidelines detail board
and senior management responsibilities when outsourcing "material"
banking functions.
The Monetary Authority of Singapore (MAS) is
accepting comments by April 12th, 2004.
Outsourcing
functions are material when, if disrupted, they have the potential
to significantly impact ‘business operations, reputation,
or profitability.’
Factors identified in the consultation paper
include importance of the business activity (e.g., in terms of income
and profit); potential impact of the outsourcing on earnings, liquidity,
and risk profile; and cost of outsourcing as a proportion of total
operating costs.
Where board and senior managers determine that
outsourcing is material, the government "expects an institution
to demonstrate that it has established a robust risk management
framework" for identification, measurement, monitoring and
control of risks and risk mitigation strategies.
The consultation paper analyses three
governance objectives:
* First, ultimate responsibility rests with the board and senior
management. Hence, corporate leaders may delegate day-to-day operational
duties to the service provider, but not responsibility and accountability
for strategic risk and security objectives.
* Second, board and senior management are responsible
for evaluating the most critical business risks, including adequacy
of insurance and strength of internal controls in service provider
operations. The guidelines focus in particular on business continuity,
including the ability to retain control in the event of a crisis.
Geopolitical risks could undermine business functioning even where
service providers portray high levels of competence and professionalism.
* Third, legal and business agreements must
memorialise appropriate audit, control, compliance, and testing
expectations. Here, too, the board and senior management must ensure
that policies and practices are in place to address legal contingencies.
These may cover subcontracting by the service provider, performance
standards and targets defined in terms of service levels, and default
terminations.
Although the guidelines are limited to banking activities, the consultation
paper offers an excellent corporate model for governing complex
outsourcing relationships in other critical infrastructure sectors.
The MAS supervises Singapore's banking, insurance,
securities and futures industries, and develops strategies in partnership
with the private sector to promote Singapore as an international
financial centre. MAS also manages monetary policy, issues currency,
and oversees foreign reserves and the issuance of government securities.
Source: Zeichner Risk Assessment Newsletter.
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•Date:
16th March 2004 •Region: SE Asia •Type:
Article •Topic: Financial
sector
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