Learnings from the Superstorm

From the FSOC 2013 Annual Report with minor paraphrasing…

• Planning and testing: It is important that your company and all of your important counterparties, vendors, and sub contractees, fully understand the functionality of contingency systems, and that key operations and business personnel communicate efficiently to assure enterprise-wide clarity. Expanded testing exercises would enhance assurance of failover reliability. Such testing should involve all parties inside and outside your firm that you depend upon to continue functioning, and should also involve providers of essential services such as power, water, and telecommunications.

• Incident management: Protocols for assuring a timely decision on whether and when to close or open the company would benefit from review and streamlining by the responsible parties. Likewise, protocols for assuring timely decisions within the firm on whether and when to leverage back-up sites would benefit from continued regular testing. Furthermore, operational interdependencies need to be fully incorporated in the decision-making process.

• Personnel: The resilience of critical components of the company requires geographic dispersal of both electronic systems and personnel sufficient to enable an organization to operate despite the occurrence of a wide-scale disruption affecting the metropolitan or geographic area of the organization’s primary operations, including communities economically integrated with, adjacent to, or within normal commuting distance of the primary operations area. Organizations, including major firms, need to continuously and rigorously analyze their routine positioning and emergency repositioning of key management and staff. This is an ongoing requirement as technology, market structure, and institutions evolve rapidly. Developed business continuity plans should be implemented, and key staff should be sent to disaster recovery sites when there is advance notice of events.

• Dependencies: Cross-industry interdependencies require constant review, reassessment, and improvement by organizations to mitigate the impact of energy, power, transport, and communications failures during severe incidents, and to help ensure reliable redundancy.

FROM THE ERM SYMPOSIUM IN CHICAGO

Post to Financial Training

• ERM Symposium Take aways

Posts to WillisWire:

• Has Risk Management become a Spectator Sport
• Actuarial Professional Risk Management
• ERM For Financial Intermediaries

Tweets:

1. Neil Cantle ‏@NJCantle 24 Apr

   Former FDIC Chairman Sheila Bair speaking at #ermsymposium warns #SolvencyII against internal models as they encouraged banks to take risk
2. Max Rudolph ‏@maxrudolph 24 Apr

   What happened to last year’s discussion of a country CRO at the #ermsymposium?
3. Max Rudolph ‏@maxrudolph 24 Apr

   Speaker from Fed at #ermsymposium says CTE no good since you don’t know distribution. How was the product priced? Not with stress tests!

   Retweeted by SocietyofActuaries

4. Neil Cantle ‏@NJCantle 23 Apr

   Seems that insurance industry may need to save up more cash to cover Nat Cat if forecasts on climate change are right! #ermsymposium
5. Max Rudolph ‏@maxrudolph 23 Apr

   Systemic risk decreases with transparency. #ermsymposium
6. Neil Cantle ‏@NJCantle 23 Apr

   So, we trust national security to causal models because data does not work. But we trust financial systems to statistics. #ermsymposium
7. Neil Cantle ‏@NJCantle 23 Apr

   Just hearing all the great things about Bayesian models…expert judgement, ease of communication to C-suite #ermsymposium #Bayesrules

   1. Dave Ingram ‏@dingramerm 23 Apr Must look at risk measures in the context of your business model. C Lawrence #ermsymposium
   2. Dave Ingram ‏@dingramerm 23 Apr

      Need to invest in the future of risk profession. Mark Abbott #ermsymposium
   3. K Andemichael ‏@that_art_guy 21 Mar

      I just heard the coolest story from Hall of Achievement Inductee Gary Peterson #ERMSymposium pic.twitter.com/1un0ZwJl1D
   4. Milliman, Inc. ‏@millimaninsight 20 Apr 12

      Neil Cantle: Complex adaptive systems are more than the sum of their parts. #ERMSymposium http://www.tout.com/m/nphp8d 
   5. Risk Institute ‏@riskinstitute 20 Apr 12

      What is the biggest misconception about enterprise risk management? http://bit.ly/JUbWb9  #ERMSymposium #ERM #risk

      Retweeted by Milliman, Inc.

   6. Risk Institute ‏@riskinstitute 18 Apr 12

      What role does economic capital modeling play in your organization? http://bit.ly/ISWFM7  #ERMSymposium #ERM

      Retweeted by Neil Cantle and 1 other

   7. Max Rudolph ‏@maxrudolph 18 Apr 12

      Business Insurance article focuses on the Emerging Risks Survey and includes some quotes from me. #ERMSymposium http://lnkd.in/M2P3xv 
   8. Max Rudolph ‏@maxrudolph 18 Apr 12

      CFO magazine article quoting me and talking about the Emerging Risks Survey! #ERMSymposium http://lnkd.in/-g-Dar 

1. CRO needs to have a 360 degree view of risk. #ermsymposium
   from Chicago, IL Dave Ingram ‏@dingramerm 24 Apr
2. New risk: longevity risk transfer products take a risk that was regulated into non-regulated areas. S Wason #ermsymposium from Chicago, IL Dave Ingram ‏@dingramerm 24 Apr
3. Companies do not always believe in their own mortality which undermines any risk mgt culture. #ermsymposium
   from Chicago, IL Dave Ingram ‏@dingramerm 24 Apr
4. Interconnectedness is THE issue for financial regulation going forward. #ermsymposium from Chicago, IL Dave Ingram ‏@dingramerm 24 Apr
5. CEO needs to be very hands on with risk. Deniability is not an option. S Bair #ermsymposium from Chicago, IL Dave Ingram ‏@dingramerm 24 Apr
6. Predictive analytics in US healthcare #ermsymposium from Illinois, US Dave Ingram ‏@dingramerm 24 Apr
7. Canadians using ERM to improve financial management of health firms. #ermsymposium Dave Ingram ‏@dingramerm 23 Apr
8. Professional Standards for Actuarial Risk Managers effective May 1, 2013 http://lnkd.in/mYwr6d Dave Ingram ‏@dingramerm 23 Apr
9. Too many think the risk equations are a closed form solution for the future when they are really about the past. M McCarthy #ermsymposium Dave Ingram ‏@dingramerm 23 Apr
10. When you crossed a limit you HAD to take an ACTION. B Mark #ermsymposium from Chicago, IL Dave Ingram ‏@dingramerm 23 Apr
11. Key goal of regulators is now financial stability. Zero tolerance for “fat tailed” failure. C Lawrence #ermsymposium
    from Chicago, IL Dave Ingram ‏@dingramerm 23 Apr
12. Bank returns jumped from 7% to 20% in 1970s & believed that risk was under control. C Lawrence #ermsymposium Dave Ingram ‏@dingramerm 23 Apr
13. Biggest risks are when we choose not know about potential problems that we did know about. Turning off fire alarms. W Fisher #ermsymposium Dave Ingram ‏@dingramerm 23 Apr
14. ERM can find offsetting risks and notionally create capital and opportunity. This gets enthusiastic buy in from mgt. M Stein #ermsymposium Dave Ingram ‏@dingramerm 23 Apr
15. The ERM program needs to show success on the opportunity side ot risk. J Kollar #ermsymposium Dave Ingram ‏@dingramerm 23 Apr
16. Accounting can cloud risk issues. Challenge to reconcile different statement. M Stein #ermsymposium from Chicago, IL Dave Ingram ‏@dingramerm 23 Apr
17. Disconnect between economics and accounting a challenge for ERM. Makes it harder to get buy in for ERM C Gilbert #ermsymposium Dave Ingram ‏@dingramerm 23 Apr
18. CRO Council papers Model Validation & Emerging Risks M Stein #ermsymposium Dave Ingram ‏@dingramerm 23 Apr
19. Key for CRO to be able to create a coherent summary of risk information for board M Stein #ermsymposium Dave Ingram ‏@dingramerm 23 Apr
20. Get board involved asking the risk questions. This create engagement in the organization to answer those questions W Fisher #ermsymposium Dave Ingram ‏@dingramerm 23 Apr
21. Wayne Fisher addressing Risk Profile at CRO panel #ermsymposium

But even with all those tweets, #ermsymposium did not make it to the top list of trending categories

Provisioning – Packing for your trip into the future

There are two levels of provisioning for an insurer.  Reserves and Risk Capital.  The two are intimately related.  In fact, in some cases, insurers will spend more time and care in determining the correct number for the sum of the two, called Total Asset Requirement (TAR) by some.

Insurers need an realistic picture of future obligations long before the future is completely clear. This is a key part of the feedback mechanism.  The results of the first year of business is the most important indication of business success for non-life insurance.  That view of results depends largely upon the integrity of the reserve value.  This feedback information effects performance evaluation, pricing for the next year, risk analysis and capital adequacy analysis and capital allocation.

The other part of provisioning is risk capital.  Insurers also need to hold capital for less likely swings in potential losses.  This risk capital is the buffer that provides for the payment of policyholder claims in a very high proportion of imagined circumstances.  The insurance marketplace, the rating agencies and insurance regulatory bodies all insist that the insurer holds a high buffer for this purpose.

In addition, many valuable insights into the insurance business can be gained from careful analysis of the data that is input to the provisioning process for both levels of provisioning.

However, reserves are most often set to be consistent with considerations.  Swings of adequate and inadequate pricing is tightly linked to swings in reserves.  When reserves are optimistically set capital levels may reflect same bias. This means that inadequate prices can ripple through to cause deferred recognition of actual claims costs as well as under provisioning at both levels.  This is more evidence that consideration is key to risk management.

There is often pressure for small and smooth changes to reserves and risk capital but information flows and analysis provide jumps in insights both as to expectations for emerging losses as well as in terms of methodologies for estimation of reserves and capital.  The business pressures may threaten to overwhelm the best analysis efforts here.  The analytical team that prepares the reserves and capital estimates needs to be aware of and be prepared for this eventuality.  One good way to prepare for this is to make sure that management and the board are fully aware of the weaknesses of the modeling approach and so are more prepared for the inevitable model corrections.

Insurers need to have a validation process to make sure that the sum of reserves and capital is an amount that provides the degree of security that is sought.  Modelers must allow for variations in risk environment as well as the impact of risk profile, financial security and risk management systems of the insurer in considering the risk capital amount.  Changes in any of those elements may cause abrupt shifts in the amount of capital needed.

The Total Asset Requirement should be determined without regard to where the reserves have been set so that risk capital level does not double up on redundancy or implicitly affirm inadequacy of reserves.

The capital determined through the Provisioning process will usually be the key element to the Risk Portfolio process.  That means that accuracy in the sub totals within the models are just as important as the overall total.  The common practice of tolerating offsetting inadequacies in the models may totally distort company strategic decision making.

This is one of the seven ERM Principles for Insurers.

Does Anyone Care about Risk Appetite?

RISKVIEWS got a private comment on the Risk Portfolio post. The comment can be summed up by the title above.

And if you think about the insights about ERM from the Plural Rationality discussion, you might echo that question.

If your risk attitude is what we call MAXIMIZER, then you will believe that you should be able to accept as much adequately priced risk as you can find.

If your risk attitude is what we call CONSERVATOR, then you will believe that you should mostly accept only risks that are very similar to what you write already, to what you are comfortable with.  You might fear that setting an appetite would improperly encourage folks to take more risk even it it does not really fit that very stringent criteria.

If your risk attitude is what we call PRAGMATIST, then you will believe that it is a waste of time to set down a rule like that in advance.  How would you know what the opportunities will be in the future?  You might easily want to accept much more or much less.  You would think that it is a waste of time to worry about such an unknowable issue.

Only the companies that are driven by what we call the MANAGERS would embrace the risk appetite idea.  They would say that you must have a risk appetite for your ERM program to have any meaning.  Many regulators have the same MANAGER risk attitude.  They agree with the fundamental idea of ERM, with the idea that risk managers are needed to assist insurance company managers, to assess risks and to make sure that the insurer does not take too much risk.  The risk managers should also be able to help the top management of the company to select the corporate strategic balance, reflecting the best combination of risks to optimize the risk reward balance of the company.

And MANAGERS will do the best for the company when they manage the risks of the firm during times of moderate volatility.  Then their choices of risks will likely perform just as their models will predict.  However in times when opportunities are best, the MANAGERS will doubtless hold the company back from the sort of gains in profitable business that the MAXIMIERS will achieve in the companies that they run.  And in times when the red ink is running all over, the MANAGERS will urge insufficient caution and will see larger losses than their models would indicate.

In the sort of uncertain times that we have lived with for 5 years now, the MANAGER’s models will not be able to adequately point the way either.  Results will languish or bounce unexpectedly.

But it is just not true that nobody cares about Risk Appetite.

ERM Control Cycle

The seven principles of ERM for Insurers can be seen as forming an Enterprise Risk Control cycle.

The cycle starts with assessing and planning for risk taking.  That process may include the Diversification principle and/or the Portfolio principle.

Next to the steps of setting Considerations and Underwriting the risks.  These steps are sometimes operated together and sometimes separate, usually depending upon the degree to which the risks are  small and homogeneous or large and unique.

The Risk Control cycle is then applied to the risks that have been accepted.  That step is needed because even if a risk is properly priced and appropriately accepted, the insurer will want to manage the aggregate amount of such risks.  Within the risk control cycle, there is a risk mitigation step and within that step an insurer may choose to reduce their total risk or to increase their risk taking capacity.

Risks that have been accepted through the underwriting process and that the insurer is retaining after the risk control cycle process must be assessed for Provisioning, both for reserve and capital.

Finally, for this discussion of the ERM Cycle, the insurer needs to consider whether there are additional risks that have been unknowingly accepted that may emerge in the future.  The Future risk principle provides a path for that step.

For the ERM Cycle, there is actually no such thing as FINALLY.  As a cycle, it repeats infinitely.  The picture above has many two headed arrows in addition to the one way arrows that represent a single circular process.

The ERM idea sits in the middle of these seven principles.  The ERM idea is the idea that an insurer will follow a cycle like this for all of the risks of the insurer and in addition for the aggregation of all risks.  This will be done to protect all of the stakeholders of the insurers, policyholders, stockholders, bondholders, management, employees and communities to the greatest extent that their sometimes contradictory interests allow.

Most firms will put different degrees of emphasis on different elements.  Some will have very faint arrows between ERM and some of the other principles.  Some insurers will neglect some of these principles completely.

It may be that the choice of which principles to emphasize are tightly linked with their view of the risk environment.

This a part of the discussion of the seven ERM Principles for Insurers

Risk Portfolio Management

In 1952, Harry Markowitz wrote the article “Portfolio Selection” which became the seed for the theory called Modern Portfolio Theory. Modern Portfolio Theory (MPT) promises a path to follow to achieve the maximum return for a given level of risk for an investment portfolio.

It is not clear who first thought to apply the MPT ideas to a portfolio of risks in an insurer. In 1974, Gustav Hamilton of Sweden’s Statsforetag proposed the “risk management circle” to describe the interaction of all elements in the risk management process, including assessment, control, financing and communication. In 1979, Randell Brubaker wrote about “Profit Maximization for a multi line Property/Liability Company.” Since then, the idea of risk and reward optimization has become to many the actual definition of ERM.

Standard & Poor’s calls the process “Strategic Risk Management”.

“Strategic Risk Management is the Standard & Poor’s term for the part of ERM that focuses on both the risks and returns of the entire firm. Although other aspects of ERM mainly focus on limiting downside, SRM is the process that will produce the upside, which is where the real value added of ERM lies.“

The Risk Portfolio Management process is nothing more or less than looking at the expected reward and loss potential for each major profit making activity of an insurer and applying the Modern Portfolio Management ideas of portfolio optimization to that risk and reward information.

At the strategic level, insurers will leverage the risk and reward knowledge that comes from their years of experience in the insurance markets as well as from their enterprise risk management (ERM) systems to find the risks where their company’s ability to execute can produce better average risk-adjusted returns. They then seek to optimize the risk/reward mix of the entire portfolio of insurance and investment risks that they hold. There are two aspects of this optimization process. First is the identification of the opportunities of the insurer in terms of expected return for the amount of risk. The second aspect is the interdependence of the risks. A risk with low interdependency with other risks may produce a better portfolio result than another risk with a higher stand alone return on risk but higher interdependence.

Proposals to grow or shrink parts of the business and choices to offset or transfer different major portions of the total risk positions can be viewed in terms of risk-adjusted return. This can be done as part of a capital budgeting/strategic resource allocation exercise and can be incorporated into regular decision-making. Some firms bring this approach into consideration only for major ad hoc decisions on acquisitions or divestitures and some use it all the time.

There are several common activities that may support the macro- level risk exploitation.

Economic Capital
Economic capital (EC) flows from the Provisioning principle. EC is often calculated with a comprehensive risk model consistently for all of the actual risks of the company. Adjustments are made for the imperfect correlation of the risks. Identification of the highest-concentration risks as well as the risks with lower correlation to the highest-concentration risks is risk information that can be exploited. Insurers may find that they have an advantage when adding risks to those areas with lower correlation to their largest risks if they have the expertise to manage those risks as well as they manage their largest risks.

Risk-adjusted product pricing
Another part of the process to manage risk portfolio risk reward involves the Consideration principle. Product pricing is “risk-adjusted” using one of several methods. One such method is to look at expected profits as a percentage of EC resulting in an expected return-to-risk capital ratio. Another method reflects the cost of capital associated with the economic capital of the product as well as volatility of expected income. The cost of capital is determined as the difference between the price to obtain capital and the rate of investment earnings on capital held by the insurer. Product profit projections then will show the pure profit as well as the return for risk of the product. Risk-adjusted value added is another way of approaching risk-adjusted pricing.

Capital budgeting
The capital needed to fulfill proposed business plans is projected based on the economic capital associated with the plans. Acceptance of strategic plans includes consideration of these capital needs and the returns associated with the capital that will be used. Risk exploitation as described above is one of the ways to optimize the use of capital over the planning period. The allocation of risk capital is a key step in this process.

Risk-adjusted performance measurement (RAPM)
Financial results of business plans are measured on a risk-adjusted basis. This includes recognition of the cost of holding the economic capital that is necessary to support each business as reflected in risk-adjusted pricing as well as the risk premiums and loss reserves for multi-period risks such as credit losses or casualty coverages. This should tie directly to the expectations of risk- adjusted profits that are used for product pricing and capital budgeting. Product pricing and capital budgeting form the expectations of performance. Risk-adjusted performance measurement means actually creating a system that reports on the degree to which those expectations are or are not met.

For non-life insurers, Risk Portfolio Management involves making strategic trade-offs between insurance, credit (on reinsurance ceded) and all aspects of investment risk based on a long-term view of risk-adjusted return for all of their choices.

Insurers that do not practice Portfolio Risk Management usually fail to do so because they do not have a common measurement basis across all of their risks. The recent move of many insurers to develop economic capital models provides a powerful tool that can be used as the common risk measure for this process. Economic capital is most often the metric used to define risk in the risk/reward equation of insurers.

Some insurers choose not to develop an EC model and instead rely upon rating agency or regulatory capital formulas. The regulatory and rating agency capital formulas are by their nature broad market estimates of the risk capital of the insurer. These formulae will over-state the capital needs for some of the insurer’s activity and understate the needs for others. The insurer has the specific data about their own risks and can do a better job of assessing their risks than any outsider could ever do. In some cases, insurers took high amounts of catastrophe exposure or embedded guarantee and option risks, which were not penalized in the generic capital formulas. In the end, some insurers found that they had taken much more risk than their actual loss tolerance or capacity.

Risk Portfolio management provides insurers with the framework to take full advantage of the power of diversification in their risk selection. They will look at their insurance and investment choices based on the impact, after diversification, on their total risk/reward profile. These insurers will also react to the cycles in risk premium that exist for all of their different insurance risks and for all of their investment risks in the context of their total portfolio.

Sales of most insurance company products result in an increase in the amount of capital needed by the business due to low or negative initial profits and the need to support the new business with Economic Capital. After the year of issue, most insurance company products will show annual releases of capital both due to the earnings of the product as well as the release of supporting capital that is no longer needed due to terminations of prior coverages. The net capital needs of a business arise when growth (new sales less terminations) is high and/or profits are low and capital is released when growth is low and/or profits are high.

The definition of the capital needs for a product is the same as the definition of distributable earnings for an entire business: projected earnings less the increase in Economic Capital. The capital budgeting process will then focus on obtaining the right mix of short and long term returns for the capital that is needed for each set of business plans.

Both new and existing products can be subjected to this capital budgeting discipline. A forecast of capital usage by a new product can be developed and used as a factor in deciding which of several new products to develop. In considering new and existing products, capital budgeting may involve examining historic and projected financial returns.

Pitfalls of Risk Portfolio Management

In theory, optimization processes can be shown to produce the best results for practitioners. And for periods of time when fluctuations of experience are moderate and fall comfortably within the model parameters, continual fine tuning and higher reliance on the modeled optimization recommendations produce ever growing rewards for the expert practitioner. However, model errors and uncertainties are magnified when management relies upon the risk model to lever up the business. And at some point, the user of complex risk models will see that levering up their business seems to be a safe and profitable way to operate. When volatility shifts into a less predictable and/or higher level, the highly levered company can find it self quickly in major trouble.

Even without major deviations of experience, the Risk Portfolio Management principles can lead to major business disruptions. When an insurer makes a major change in its risk profile through an acquisition or divestiture of a large part of their business, the capital allocation of all other activities may shift drastically. Strict adherence to theory can whipsaw businesses as the insurer makes large changes in business.

Insurers need to be careful to use the risk model information to inform strategic decisions without overreliance and abdication of management judgment. Management should also push usage of risk and reward thinking throughout the organization. The one assumption that seems to cause the most trouble is correlation. The saying goes that “in a crisis, all correlations go to one”. If the justification for a major strategic decision is that correlations are far from one, management should take note of the above saying and prepare accordingly. In addition management should study the variability of correlations over time. They will find that correlations are often highly unreliable and this should have a major impact on the way that they are used in the Risk Portfolio Management process.

Risk Portfolio Management is one of the Seven ERM Principles for Insurers

Future Uncertainty

Often called emerging risks. Going back to Knight’s definitions of Risk and Uncertainty, there is very little risk contained in these potential situations.  Emerging risks are often pure uncertainty.  Humans are good at finding patterns.  Emerging risks are breaks in patterns.

What to Do about Emerging Risks…

Emerging risks are defined by AM Best as “new or evolving risks that are difficult to manage because their identification, likelihood of occurrence, potential impacts, timing of occurrence or impact, or correlation with other risks, are highly uncertain.” An example from the past is asbestos; other current examples could be problems deriving from nanotechnology, genetically modified food, climate change, etc. Lloyd’s, a major sufferer from the former emerging risk of asbestos, takes emerging risks very seriously. They think of emerging risks as “an issue that is perceived to be potentially significant but which may not be fully understood or allowed for in insurance terms and conditions, pricing, reserving or capital setting”.

What do the rating agencies expect?

AM Best says that insurers need “sound risk management practices relative to its risk profile and considering the risks inherent in the liabilities it writes, the assets it acquires and the market(s) in which it operates, and takes into consideration new and emerging risks.” In 2013, Best has added a question asking insurers to identify emerging risks to the ERM section of the SRQ. Emerging Risks Management has been one of the five major pillars of the Standard & Poor’s Insurance ERM ratings criteria since 2006.

How do you identify emerging risks?

A recent report from the World Economic Forum, The Global Risks 2012 report is based on a survey of 469 experts from industry, government, academia and civil society that examines 50 global risks. Those experts identified 8 of those 50 risks as having the most significance over the next 10 years:

•   Chronic fiscal imbalances
•   Cyber attacks
•   Extreme volatility in energy and agriculture prices
•   Food shortage crises
•   Major systemic financial failure
•   Rising greenhouse gas emissions
•   Severe income disparity
•   Water supply crises

This survey method for identifying or prioritizing risks is called the Delphi method and can be used by any insurer. Another popular method is called environmental scanning which includes simply reading and paying attention for unusual information about situations that could evolve into future major risks.

What can go wrong?

Many companies do not have any process to consider emerging risks.  At those firms, managers usually dismiss many possible emerging risks as impossible.  It may be the company culture to scoff at the sci fi thinking of the emerging risks process.  The process Taleb describes of finding ex post explanation for emerging Black Swan risks is often the undoing of careful plans to manage emerging risk.  In addition, lack of imagination causes some managers to conclude that the past worst case is the outer limit for future losses.

What can you do about emerging risks?

The objectives for emerging risks management are just the same as for other more well-known risks: to reduce the frequency and severity of future losses. The uncertain nature of emerging risks makes that much more difficult to do cost effectively. Insurers can use scenario testing to examine potential impact of emerging risks and to see what actions taken in advance of their emergence might lessen exposures to losses. This scenario testing can also help to identify what actions might lessen the impact of an unexpected loss event that comes from a very rapidly emerging risk. Finally, insurers seek to identify and track leading indicators of impending new risk emergence.

Reinsurance is one of the most effective ways to protect against emerging risks, second only to careful drafting of insurance contract terms and conditions

Many of the largest insurers and reinsurers have developed very robust practices to identify and to prepare for emerging risks.  Other companies can learn from the insurers who practice emerging risk management and adapt the same processes to their emerging risks.

Normal risk control processes focus on everyday risk management, including the management of identifiable risks and/or risks where uncertainty and unpredictability are mitigated by historical data that allow insurers to estimate loss distribution with reasonable confidence. Emerging risk management processes take over for risks that do not currently exist but that might emerge at some point due to changes in the environment. Emerging risks may appear abruptly or slowly and gradually, are difficult to identify, and may for some time represent an ill formed idea more than factual circumstances. They often result from changes in the political, legal, market, or physical environment, but the link between cause and effect is fully known in advance. An example from the past is asbestos; other examples could be problems deriving from nanotechnology, genetically modified food, climate change, etc. 
For these risks, normal risk identification and monitoring will not work because the likelihood is usually completely unknown. Nevertheless, past experience shows that when they materialize, they have a significant impact on the insurers and therefore cannot be excluded from a solid risk management 
program. So insurers have implemented unique specific strategies and approaches to cope with them properly.

Identifying emerging risks

Emerging risks have not yet materialized or are not yet clearly defined and can appear abruptly or very slowly. Therefore, having some sort of early warning system in place, methodically identified either through internal or external sources, is very important. To minimize the uncertainty surrounding these risks, insurers will consistently gather all existing relevant information to amass preliminary evidence of emerging risks, which would allow the insurer to reduce or limit growth of exposure as the evidence becomes more and more certain.  However, Insurers practicing this discipline will need to be aware of the cost of false alarms.

Assessing their significance

Assess the relevance (i.e. potential losses) of the emerging risks linked to a company’s commitment— which classes of business and existing policies would be affected by the materialization of the risk—and continue with the assessment of the potential financial impact, taking into account potential correlation with other risks already present in the firm. For an insurer, the degree of concentration and correlation of the risks that they have taken on from their customers are two important parameters to be considered; the risk in question could be subject to very low frequency/high intensity manifestations, but if exposure to that particular risk is limited, then the impact on the company may not be as important. On the other hand, unexpected risk correlations should not be underestimated; small individual exposures can coalesce into an extreme risk if underlying risks are highly interdependent. When developing extreme scenarios, some degree of imagination to think of unthinkable interdependencies could be beneficial.

A further practice of insurers is to sometimes work backwards from concentrations to risks. Insurers might envision risks that could apply to their concentrations and then track for signs of risk emergence in those areas. Some insurers set risk limits for insurance concentrations that are very similar to investment portfolio credit limits, with maximum concentrations in specific industries in geographic or political regions. In addition, just as investment limits might restrict an insurer’s debt or equity position as a percentage of a company’s total outstanding securities, some insurers limit the percentage of coverage they might offer in any of the sectors described above.

Define appropriate responses

Responses to emerging risks might be part of the normal risk control process, i.e., risk mitigation or transfer, either through reinsurance (or retrocession) in case of insurance risks, through the financial markets for financial risks, or through general limit reduction or hedging. When these options are not available or the insurer decides not to use them, it must be prepared to shoulder significant losses, which can strain a company’s liquidity.  Planning access to liquidity is a basic part of emerging risk management.  Asset-selling priorities, credit facilities with banks, and notes programs are possible ways of managing a liquidity crisis.

Apart from liquidity crisis management, other issues exist for which a contingency plan should be identified in advance. The company should be able to quickly estimate and identify total losses and the payments due. It should also have a clear plan for settling the claims in due time so as to avoid reputation issues. Availability of reinsurance is also an important consideration: if a reinsurer were exposed to the same risks, it would be a sound practice for the primary insurer to evaluate the risk that the reinsurer might delay payments.

Advance Warning Process

For the risks that have identified as most significant and where the insurer has developed coherent contingency plans, the next step is to create and install an advanced warning process.  To do that, the insurer identifies key risk indicators that provide an indication of increasing likelihood of a particular emerging risk.

Learn

Finally, sound practices for managing emerging risks include establishing procedures for learning from past events. The company will identify problems that appeared during the last extreme event and identify improvements to be added to the risk controls.  In addition, expect to get better at each step of the emerging risk process with time and experience.

But emerging risk management costs money.  And the costs that are most difficult to defend are the emerging risks that never emerge.  A good emerging risk process will have many more misses than hits.  Real emerged risks are rare.  A company that is really taking emerging risks seriously will be taking actions on occasion that cost money to perform and possibly include a reduction in the risks accepted and the attendant profits.  Management needs to have a tolerance for these costs.  But not too much tolerance.

 

This is one of the seven ERM Principles for Insurers

Getting Paid for Risk Taking

Consideration for accepting a risk needs to be at a level that will sustain the business and produce a return that is satisfactory to investors.

Investors usually want additional return for extra risk.  This is one of the most misunderstood ideas in investing.

“In an efficient market, investors realize above-average returns only by taking above-average risks.  Risky stocks have high returns, on average, and safe stocks do not.”

Baker, M. Bradley, B. Wurgler, J.  Benchmarks as Limits to Arbitrage: Understanding the Low-Volatility Anomaly

But their study found that stocks in the top quintile of trailing volatility had real return of -90% vs. a real return of 1000% for the stocks in the bottom quintile.

But the thinking is wrong.  Excess risk does not produce excess return.  The cause and effect are wrong in the conventional wisdom.  The original statement of this principle may have been

“in all undertakings in which there are risks of great losses, there must also be hopes of great gains.”
Alfred Marshall 1890 Principles of Economics

Marshal has it right.  There are only “hopes” of great gains.  These is no invisible hand that forces higher risks to return higher gains.  Some of the higher risk investment choices are simply bad choices.

Insurers opportunity to make “great gains” out of “risks of great losses” is when they are determining what consideration, or price, that they will require to accept a risk.  Most insurers operate in competitive markets that are not completely efficient.  Individual insurers do not usually set the price in the market, but there is a range of prices at which insurance is purchased in any time period.  Certainly the process that an insurer uses to determine the price that makes a risk acceptable to accept is a primary determinant in the profits of the insurer.  If that price contains a sufficient load for the extreme risks that might threaten the existence of the insurer, then over time, the insurer has the ability to hold and maintain sufficient resources to survive some large loss situations.

One common goal conflict that leads to problems with pricing is the conflict between sales and profits.  In insurance as in many businesses, it is quite easy to increase sales by lowering prices.  In most businesses, it is very difficult to keep up that strategy for very long as the realization of lower profits or losses from inadequate prices is quickly realized.  In insurance, the the premiums are paid in advance, sometimes many years in advance of when the insurer must provide the promised insurance benefits.  If provisioning is tilted towards the point of view that supports the consideration, the pricing deficiencies will not be apparent for years.  So insurance is particularly susceptible to the tension between volume of business and margins for risk and profits,
and since sales is a more fundamental need than profits, the margins often suffer.
As just mentioned, insurers simply do not know for certain what the actual cost of providing an insurance benefit will be.  Not with the degree of certainty that businesses in other sectors can know their cost of goods sold.  The appropriateness of pricing will often be validated in the market.  Follow-the-leader pricing can lead a herd of insurers over the cliff.  The whole sector can get pricing wrong for a time.  Until, sometimes years later, the benefits are collected and their true cost is know.

“A decade of short sighted price slashing led to industry losses of nearly $3 billion last year.”  Wall Street Journal June 24, 2002

Pricing can also go wrong on an individual case level.  The “Winners Curse”  sends business to the insurer who most underimagines riskiness of a particular risk.

There are two steps to reflecting risk in pricing.  The first step is to capture the expected loss properly.  Most of the discussion above relates to this step and the major part of pricing risk comes from the possibility of missing that step as has already been discussed.  But the second step is to appropriately reflect all aspects of the risk that the actual losses will be different from expected.  There are many ways that such deviations can manifest.

The following is a partial listing of the risks that might be examined:

• Type A Risk—Short-Term Volatility of cash flows in 1 year

• Type B Risk—Short -Term Tail Risk of cash flows in 1 year
• Type C Risk—Uncertainty Risk (also known as parameter risk)
• Type D Risk—Inexperience Risk relative to full multiple market cycles
• Type E Risk—Correlation to a top 10
• Type F Risk—Market value volatility in 1 year
• Type G Risk—Execution Risk regarding difficulty of controlling operational
losses
• Type H Risk—Long-Term Volatility of cash flows over 5 or more years
• Type J Risk—Long-Term Tail Risk of cash flows over 5 years or more
• Type K Risk—Pricing Risk (cycle risk)
• Type L Risk—Market Liquidity Risk
• Type M Risk—Instability Risk regarding the degree that the risk parameters are
stable

See “Risk and Light” or “The Law of Risk and Light“

There are also many different ways that risk loads are specifically applied to insurance pricing.  Three examples are:

• Capital Allocation – Capital is allocated to a product (based upon the provisioning) and the pricing then needs to reflect the cost of holding the capital.  The cost of holding capital may be calculated as the difference between the risk free rate (after tax) and the hurdle rate for the insurer.  Some firms alternately use the difference between the investment return on the assets backing surplus (after tax) and the hurdle rate.  This process assures that the pricing will support achieving the hurdle rate on the capital that the insurer needs to hold for the risks of the business.  It does not reflect any margin for the volatility in earnings that the risks assumed might create, nor does it necessarily include any recognition of parameter risk or general uncertainty.
• Provision for Adverse Deviation – Each assumption is adjusted to provide for worse experience than the mean or median loss.  The amount of stress may be at a predetermined confidence interval (Such as 65%, 80% or 90%).  Higher confidence intervals would be used for assumptions with higher degree of parameter risk.  Similarly, some companies use a multiple (or fraction) of the standard deviation of the loss distribution as the provision.  More commonly, the degree of adversity is set based upon historical provisions or upon judgement of the person setting the price.  Provision for Adverse Deviation usually does not reflect anything specific for extra risk of insolvency.
• Risk Adjusted Profit Target – Using either or both of the above techniques, a profit target is determined and then that target is translated into a percentage of premium of assets to make for a simple risk charge when constructing a price indication.

The consequences of failing to recognize as aspect of risk in pricing will likely be that the firm will accumulate larger than expected concentrations of business with higher amounts of that risk aspect.  See “Risk and Light” or “The Law of Risk and Light“.

To get Consideration right you need to (1)regularly get a second opinion on price adequacy either from the market or from a reliable experienced person; (2) constantly update your view of your risks in the light of emerging experience and market feedback; and (3) recognize that high sales is a possible market signal of underpricing.

This is one of the seven ERM Principles for Insurers

Underwriting of risks is a key part of risk management for insurers

Underwriting is the process of reviewing and selecting risks that an insurer might accept, under what terms, and assigning those an expected cost and level of riskiness.

• Some underwriting processes are driven by statistics.  A few insurers who developed a highly statistical approach to underwriting personal auto coverages have experienced high degree of success.  With a careful mining of the data from their own claims experience, these insurers have been able to carefully subdivide rating classes into many finer classes with reliable claims expectations at different levels.  This allows them to concentrate their business on the better risks in each of the larger classes of their competitors while the competitors end up with a concentration of below average drivers in each larger class.  This statistical underwriting process is becoming a required tool to survive in personal auto and is being copied in other insurance lines.
• Many underwriting processes are highly reliant on judgment of an experienced underwriter.  Especially commercial business or other types of coverage where there is very little close commonality between one case and another.  Many insurers consider underwriting expertise to be their key corporate competency.
• Usually the underwriting process concludes with a decision on whether to make an offer to accept a risk under certain terms and at a determined price

How underwriting can go wrong:

• Insurers are often asked to “give away the pen” and allow third parties to underwrite risks on their paper. Sometimes a very sad ending to this.
• Statistical underwriting can spin out of control due to antiselection if not overseen by experienced people.  The bubble of US home mortgage securities can be seen as an extreme example of statistical underwriting gone bad.  Statistics from prior periods suggested that sub prime mortgages would default at a certain low rate.  Over time, the US mortgage market went from one with a high degree of underwriting of applicants by skilled and experienced reviewers to a process dictated by scores on credit reports and eventually the collection of data to perform underwriting stopped entirely with the no doc loans.  The theory was that the interest rate charged for the mortgages could be adjusted upwards to the point where extra interest collected could pay for the excess default claims from low credit borrowers.
• Volume incentives can work against the primary goals of underwriting.
• Insurance can be easily undone by underwriting decisions that are good risks, but much too large for the pool of other risks held by the insurer.

To get Underwriting right you need to:

• Have a clear idea of the risks that you are willing to accept, your risk preferences.  And be clear that you are going to be saying NO to risks that are outside of those preferences.
• Not let the pen get entirely out of the hand of an experienced underwriter that is trustable to make decisions in the interest of the firm, either to a computer or to a third party.
• Oversight of underwriting decisions needs to be an expectation at all levels.  The primary objective of this oversight should be to continually perfect the underwriting process and knowledge base.
• Underwriters need to be fully aware of the results of their prior decisions by regular communication with claims and reserving people.

This is one of the seven ERM Principles for Insurers

Delusions about Success and Failure

In his book, The Halo Effect: … and the Eight Other Business Delusions That Deceive Managers, author Phil Rosenzweig discusses the following 8 delusions about success:

1. Halo Effect: Tendency to look at a company’s overall performance and make attributions about its culture, leadership, values, and more.

2. Correlation and Causality: Two things may be correlated, but we may not know which one causes which.

3. Single Explanations: Many studies show that a particular factor leads to improved performance. But since many of these factors are highly correlated, the effect of each one is usually less than suggested.

4. Connecting the Winning Dots: If we pick a number of successful companies and search for what they have in common, we’ll never isolate the reasons for their success, because we have no way of comparing them with less successful companies.

5. Rigorous Research: If the data aren’t of good quality, the data size and research methodology don’t matter.

6. Lasting Success: Almost all high-performing companies regress over time. The promise of a blueprint for lasting success is attractive but unrealistic.

7. Absolute Performance: Company performance is relative, not absolute. A company can improve and fall further behind its rivals at the same time.

8. The Wrong End of the Stick: It may be true that successful companies often pursued highly focused strategies, but highly focused strategies do not necessarily lead to success.

9. Organizational Physics: Company performance doesn’t obey immutable laws of nature and can’t be predicted with the accuracy of science – despite our desire for certainty and order.

By Julian Voss-Andreae (Own work) [CC-BY-SA-3.0 (http://creativecommons.org/licenses/by-sa/3.0)%5D, via Wikimedia Commons

A good risk manager will notice that all 8 of these delusions have a flip side that applies to risk analysis and risk management.

a.  Bad results <> Bad Culture – there are may possible reasons for poor results.  Culture is one possible reason for bad results, but by far not the only one.

b.  Causation and Correlation – actually this one need not be flipped.  Correlation is the most misunderstood statistic.  Risk managers would do well to study and understand what valuable and reliable uses that there are for correlation calculations.  They are very likely to find few.

c.  Single explanations  – are sometimes completely wrong (see c. above), they can be the most important of several causes, they can be the correct and only reason for a loss, or a correct but secondary reason.  Scapegoating is a process of identifying a single explanation and quickly moving on.  Often without much effort to determine which of the four possibilities above applies to the scapegoat.  Scapegoats are sometimes chosen that make the loss event appear to be non-repeatable, therefore requiring no further remedial action.

d.  Barn door solutions – looking backwards and finding the activities that seemed to lead to the worst losses at the companies that failed can provide valuable insights or it can lead to barn door solutions that fix past problems but have no impact on future situations.

e.  Data Quality – same exact issue applies to loss analysis.  GIGO

f.  Regression to the mean – may be how you describe what happens to great performing companies, but for most firms, entropy is the force that they need to be worried about.  A firm does not need to sport excellent performance to experience deteriorating results.

g.  Concentration risk – should be what a risk manager sees when strategy is too highly concentrated.

h.  Uncertainty prevails – precision does not automatically come from expensive and complicated models.

Risk and Return – A Balancing Act

From Max Rudolph

There are similarities between value investing and enterprise risk management (ERM) methods. For some, especially portfolio managers, this may be obvious. These investors come to the table with experience using risk as a constraint while trying to optimize returns. Years of experience have taught this group that risk balances return, and that return balances risk. Value is added by creating favorable imbalances. The investor with high returns and average risk has succeeded, as has the investor reporting average returns and low risk.
Many concepts are shared between ERM and value investing. When defining risk, which is generally unique to the individual, an analyst considers uncertainty, downside risk, and optimization. Value investors look at concepts like conservative assumptions, margin of safety, and asset allocation. These concepts are comparable, and this paper uses the International Actuarial Association’s Note on enterprise risk management (ERM) for capital and solvency purposes in the insurance industry to take the reader through general ERM topics. This is followed by a comparable value investing discussion and a comparison of the two practice areas.

In some firms, a risk manager is placed in a position with little authority, limiting the benefits of ERM. A process driven ERM function can identify risks and risk owners, create a common language, and send useful reports to the Board. A stronger risk officer adds value by using transparency to understand risk interactions, scanning for emerging risks and generally keeping a focus on how an entity’s risk profile is evolving.

Continued in Value Investing and Enterprise Risk Management: Two Sides of the Same Coin

Has the risk profession become a spectator sport?

The 2013 ERM Symposium goes back to Chicago this year after a side trip to DC for 2012. This is the 11th year for the premier program for financial risk managers.   April 23 and 24th.

This year’s program has been developed around the theme, ERM: A Critical Self-Reflection, which asks:

• Has the risk profession become a spectator sport? One in which we believe we are being proactive, yet not necessarily in the right areas.
• For the most significant headlines during the past year, how was the risk management function involved?
• Since the financial crisis, has there been genuine learning and changes to how risk management functions operate?
• What are the lessons that have been learned and how are they shaping risk management today? If not, why?
• Does risk management have a seat at the table, at the correct table?
• Are risk managers as empowered as they should be?
• Is risk management asking the right questions?
• Is risk management as involved in decision making and value creation as it should be, at inception of ideas and during follow through?

On Wednesday, April 24 Former FDIC Chairman Sheila Bair will be the featured luncheon speaker

Sheila C. Bair served as the 19th chairman of the Federal Deposit Insurance Corporation for a five-year term, from June 2006 through July 2011. Bair has an extensive background in banking and finance in a career that has taken her from Capitol Hill to academia to the highest levels of government. Before joining the FDIC in 2006, she was the dean’s professor of financial regulatory policy for the Isenberg School of Management at the University of Massachusetts-Amherst since 2002.

The ERM Symposium and seminars bring together ERM knowledge from the insurance, energy and financial sectors.  Now in its 11th year, this premier global conference on ERM will offer: sessions featuring top risk management experts; seminars on hot ERM issues; ERM research from leading universities; exhibitors demonstrating their ERM services.  This program has been developed jointly by the Casualty Actuarial Society (CAS), the Professional Risk management International Association (PRMIA) and the Society of Actuaries (SOA).

Riskviews will be a speaker at three sessions out of more than 20 offered:

• Regulatory Reform: Responding to Complexity with Complexity – Andrew Haldane, executive director of Financial Stability at the Bank of England, recently made a speech at the Federal Reserve Bank of Kansas City’s Jackson Hole Economic Policy Symposium titled “The Dog and the Frisbee” warning that the growing complexity of markets and banks cannot be controlled with increasingly complex regulations. In fact, by attempting to solve the problem of complexity with additional complexity created by increased regulation, we may be missing the mark—perhaps simpler metrics and human judgment may be superior. Furthermore, in attempting to solve a complex problem with additional complexity, we may not have clearly defined or understand the problem. How does ERM fit into the solutions arsenal? Are there avenues left unexplored? Is ERM adding or minimizing complexity?
  • We are drowning in data, but can’t hope to track all the necessary variables, nor understand all or even the most important linkages. Given the wealth of data available, important signals may be lost in the overall “noise.”
  • Unintended consequences maybe lost/hidden in the maze of complexity thereby magnifying the potential impact of future events.
  • The importance of key variables changes throughout time and from situation to situation, so it’s not possible to predict in advance which ones will matter most in the next crisis.
  • We experience relatively few new crises that are mirror images of prior crises, so we really have limited history to learn how to prevent or to cure them.
  • Complex rules incent companies and individuals to “manage to the rules” and seek arbitrage, perhaps seeding the next crisis.

• Actuarial Professional Risk Management  –  The new actuarial standards for Risk Evaluation and Risk Treatment bring new help and new issues to actuaries practicing in the ERM field. For new entrants, the standards are good guidelines for preparing comprehensive analyses and reports to management. For more experienced practitioners, the standards lay out expectations for a product worthy of the highly-qualified actuary. However, meeting the standards’ expectations is not easy. This session focuses on clarifying key aspects of the standards.
• Enterprise Risk Management in Financial Intermediation  –  This session provides a framework for thinking about the rapidly evolving, some would say amorphous, subject of ERM, especially as applied at financial institutions and develops seven principles of ERM and considers their (mis)application in a variety of organizational settings. The takeaways are both foundational and practical.

Please join us for some ERM fun and excitement.

 

 

Controlling with a Cycle

No, not that kind of cycle… This kind:

This is a Risk Control Cycle.  It includes Thinking/Observing steps and Action Steps.  The only reason a sane organization would spend the time on the Assessing, Planning and Monitoring steps is so that they could be more effective with the Risk Taking, Mitigating and Responding steps.

A process capable of limiting losses can be referred to as a complete risk control process, which would usually include the following:

• Identification of risks—with a process that seeks to find all risks inherent in a insurance product, investment instrument, or other situation, rather than simply automatically targeting “the usual suspects.”
• Assess Risks – This is both the beginning and the end of the cycle.  As the end, this step is looking back and determining whether your judgment about the risk and your ability to select and manage risks is as good as you thought that it would be.  As the beginning, you look forward to form a new opinion about the prospects for risk and rewards for the next year.  For newly identified risks/opportunities this is the due diligence phase.
• Plan Risk Taking and Risk Management – Based upon the risk assessment, management will make plans for how much of each risk that the organization will plan to accept and then how much of that risk will be transferred, offset and retained.  These plans will also include the determination of limits
• Take Risks – organizations will often have two teams of individuals involved in risk taking.  One set will identify potential opportunities based upon broad guidelines that are either carried over from a prior year or modified by the accepted risk plan.  (Sales) The other set will do a more detailed review of the acceptability of the risk and often the appropriate price for accepting the risk.  (Underwriting)
• Measuring and monitoring of risk—with metrics that are adapted to the complexity and the characteristics of the risk as well as Regular Reporting of Positions versus Limits/Checkpoints— where the timing needed to be effective depends on the volatility of the risk and the rate at which the insurer changes their risk positions. Insurers may report at a granular level that supports all specific decision making and actions on a regular schedule.
• Regular risk assessment and dissemination of risk positions and loss experience—with a standard set of risk and loss metrics and distribution of risk position reports, with clear attention from persons with significant standing and authority in the organization.
• Risk limits and standards—directly linked to objectives. Terminology varies widely, but many insurers have both hard “Limits” that they seek to never exceed and softer “Checkpoints” that are sometimes exceeded. Limits will often be extended to individuals within the organization with escalating authority for individuals higher in the organizational hierarchy.
• Response – Enforcement of limits and policing of checkpoints—with documented consequences for limit breaches and standard resolution processes for exceeding checkpoints. Risk management processes such as risk avoidance for risks where the insurer has zero tolerance. These processes will ensure that constant management attention is not needed to assure compliance. However, occasional assessment of compliance is often practiced. Loss control processes to reduce the avoidable excess frequency and severity of claims and to assure that when losses occur, the extent of the losses is contained to the extent possible. Risk transfer processes, which are used when an insurer takes more risk than they wish to retain and where there is a third party who can take the risk at a price that is sensible after accounting for any counterparty risk that is created by the risk transfer process. Risk offset processes, which are used when insurer risks can be offset by taking additional risks that are found to have opposite characteristics. These processes usually entail the potential for basis risk because the offset is not exact at any time or because the degree of offset varies as time passes and conditions change, which is overcome in whole or in part by frequent adjustment to the offsetting positions. Risk diversification, which can be used when risks can be pooled with other risks with relatively low correlation. Risk costing / pricing, which involves maintaining the capability to develop appropriate views of the cost of holding a risk in terms of expected losses and provision for risk. This view will influence the risks that an insurer will take and the provisioning for losses from risks that the insurer has taken (reserves). This applies to all risks but especially to insurance risk management. Coordination of insurance profit/loss analysis with pricing with loss control (claims) with underwriting (risk selection), risk costing, and reserving, so that all parties within the insurer are aware of the relationship between emerging experience of the 
risks that the insurer has chosen to retain and the expectations that the insurer held when it chose to write and retain the risks.
• Assess Risks – and the cycle starts again.

This is one of the seven ERM Principles for Insurers

What happens if there are no new posts?

There was no plan for March to be a test of no new posts.  But when it got into the 20’s and there were no new posts, the experiment started to sound like a good idea.

So what happened?

• 2000 Visitors
• 3200 hits
• Those totals exceed December, January and February, when there were 18 new posts
• 160 different pages or posts were viewed
• 1200 of the hits were to the Risk Management Quotes page and post
• The most popular topical post was “Getting Started with a Risk Management career“

Some say “Less is More”.  In this case, None has been More.  What a surprise.