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FRM Part II · FRM Exam Part II · Governance

Under the three lines model commonly applied to credit risk governance, which activity belongs to the second line rather than the first or third?

Independent challenge of business-line exposures and aggregate portfolio reporting by the credit risk function is a second-line activity. Loan officers managing borrowers are first line, internal audit is third line, and external auditors sit outside the bank's internal lines of defence.

  1. AA loan officer collecting covenant compliance certificates from borrowers
  2. BInternal audit testing whether the credit approval process complies with policy
  3. CThe independent credit risk function challenging business-line exposures and aggregate portfolio reporting to senior managementCorrect
  4. DAn external auditor opining on loan loss provisions

Explanation

The second line is the independent risk management function that sets frameworks, challenges and reports on risk. Loan officers are first line, internal audit is third line, and external auditors are outside the three lines of the bank.

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