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FRM Part II · FRM Exam Part II · Risk Identification

A bank plans to migrate its payments platform to a new vendor system over six months. The operational risk function is asked to apply good practice for identifying risks arising from change. Which action is MOST appropriate?

The bank should assess the change's risks before approval and implementation, covering processes, people, systems and third parties, and keep updating the assessment as the project progresses. Waiting for post-launch losses is reactive, and relying on the vendor alone leaves the bank's own accountability unaddressed.

  1. AAssess risks only after go-live, when actual loss events provide objective data
  2. BPerform a risk assessment of the change before approval and implementation, covering process, people, systems and third-party impacts, and update it as the project evolvesCorrect
  3. CLimit the review to IT risks because change programs do not affect other risk categories
  4. DRely on the vendor's own risk assessment as sufficient evidence of control adequacy

Explanation

Sound practice requires identifying risks prospectively, before change is approved and implemented, across all affected dimensions, and revisiting the assessment as the project develops. Waiting for losses is reactive, limiting to IT ignores process and people effects, and relying on the vendor abandons the bank's own accountability.

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