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Condition precedent for the risk management

Bank must adopt and implement respective documents designing and regulating risk management environment before commencing with the business operations (risk management strategy, policies, and procedures).

Risk management in the bank

A bank is responsible to continuously manage all risks it has been exposed to in its operations in accordance with the law, regulations of the CBoM and best risk management practices in the bank, and must establish risk management system that provides the following:

Risk management system in a bank must correspond to the size of a bank, complexity of products and services in its operations and the level of assumed risk.

As a minimum, risk management system must include the following:

A strategy for management of risks the bank has been exposed to in its operations must include, as a minimum, the following:

Risk management policies must provide accomplishment of risk management strategy on a daily basis and have to include, as a minimum, the following:

A bank must periodically, and at least annually, review adequacy of the adopted policies and processes for management of individual risks.

The CBoM may at any given time require the bank to document processes for management of individual risks.

A bank have to clearly define, in its rules and procedures, powers and responsibilities for risk management in bank for all levels of work process and decision-making, and provide segregation of risk taking from risk identification, measurement, monitoring and control.

The CBoM may prescribe minimum requirements for the information system functioning.

A bank must designate, within its organizational structure, an organizational part or persons, depending on the size and complexity of the bank’s operations, directly responsible for individual risk management on daily basis. The organizational parts or persons will be responsible to provide reports to the bank’s board of directors on risk management activities if needed, and at least once a month.

A bank must establish and maintain reliable information system that adequately ensures gathering and processing of information for the following:

A bank needs to provide preparation of secure electronic backups of information and data on daily basis and store them on a secure location.

The CBoM may prescribe the minimum requirements for the information system functioning.

A bank shall also conduct, using several types of stress scenarios, testing of the bank’s sensitivity to individual types of risks on aggregate basis.

Stress scenario shall include, in the context of this law, assumptions on extreme changes of market and other factors, which may have significant material impact on bank’s performance.

Types of risks

The risks the bank is exposed to in its operations and for which it must establish risk management system are the following:

Liquidity risk shall be the risk that the bank will not be able to provide a sufficient amount of cash to meet its obligations as they become due, or risk that the bank may obtain cash with significant expenses to meet the matured obligations. The bank must operate so that it can meet all its obligations in cash as they become due.

Credit risk shall be the risk of incurring losses in bank operations due to the debtor’s failure to meet its obligations to the bank.

Total exposure of a bank to one party or group of related parties may not exceed 25% of bank’s own funds. The exposure of a bank to one party or group of related parties, in accordance with the CBoM regulation, shall be the total amount of all bank claims on loans and other assets, including amount of off balance sheet obligations and uncollected written off assets, decreased by the amount of claims that is secured by qualitative instruments of security of claims. The exposure of a bank to one party or group of related parties shall be considered as large if it is equal to or larger than 10% of bank’s own funds. The sum of all large exposures of a bank must not exceed 800% of bank’s own funds. The bank shall apply the following limits for the exposures to bank related parties:

Sum of the total exposure of a bank to the following parties may not exceed 20% of bank’s own funds:

Market risk shall be the probability of incurring losses in bank balance sheet and off-balance sheet financial instruments arising from changes in interest rates, foreign exchange rates, prices, indices and/or other market factors impacting the value of financial instruments, as well as the risks related with the marketability of financial instruments.

Operational risk shall be the risk of incurring losses in the bank’s operation, as a result of inadequate internal systems, processes and controls, including also inadequate information technology due to outsourcing, weaknesses and errors in performance, illegal actions and external events that may expose a bank to loss, including legal risk as well. In case of outsourcing provided through an outsourcing agreement or otherwise, a bank shall enable the CBoM, in the process of operational risk examination, review of quality of the services rendered, including the direct review with such service provider.

Country risk shall represent the possibility of incurring losses by a bank, due to inability to collect receivables from the entities outside of Montenegro, which results from political, social and economical environment of the country in which debtor has its head office or residence (hereinafter referred to as: debtor’s country). Country risk shall include:

Interest rate risk not resulting from bank trading activities shall be the risk of incurring losses in bank’s operations due to the interest rate changes for balance sheet and off balance sheet items that are not intended for trade.