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FRM Part I · FRM Exam Part I · The Governance of Risk Management

A bank's compensation scheme pays traders a large annual cash bonus based on that year's trading revenue, with no clawback or deferral. From a governance perspective drawn from the lessons of the financial crisis, which reform best addresses the main flaw?

Deferring a significant part of pay, linking it to risk-adjusted performance over several years, and allowing clawback best fixes the flaw. It aligns trader incentives with long-term firm health instead of rewarding short-term revenue that may hide tail risks which materialize later.

  1. AIncrease the bonus pool so that talent is retained during downturns
  2. BBase the bonus on revenue measured over a shorter period, such as monthly
  3. CDefer a significant portion of pay, tie it to risk-adjusted performance over a multi-year horizon, and allow clawbackCorrect
  4. DReplace all variable pay with fixed salary for only the risk management staff

Explanation

The flaw is incentive for short-term, risk-ignoring revenue. Deferral, risk adjustment and clawback align pay with long-term outcomes. A shorter measurement period worsens short-termism, and larger bonuses do not fix the misalignment.

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