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Executive Summary: The following interview is a broad review of current risk best practices on the buy side, and what lessons risk managers should have learned from the most recent crisis. As detailed in the conversation below,
The principal goals for a chief risk officer are to:
1) Enable senior management to maximize the firm’s risk-adjusted return on capital and find new opportunities.
2) Provide senior management with timely, accurate risk estimates and anticipate a robust range of potential outcomes.
3) Ensure the accuracy of the valuation of holdings and liquidity profile of each pool of capital.
4) Validate models and systems and identify and continually remediate weaknesses.
5) Provide leadership and help instill a firm-wide risk discipline.
Risk managers should have learned from the last crisis that:
1) Models are an approximation of reality and often poor ones at that.
2) Portfolio managers need to manage their liquidity profile and link it to their investment strategy.
3) Markets are dynamic, often opaque and regime shifts are occurring much more dynamically than before.
4) Risk oversight and stresses must be tailored to each underlying strategy and not simply result in top-level firm-wide views.
5) Firms must guard against complacency and periodically review all processes and data-transfer points.
DAVID SAMUELS: Can you give us a brief overview of your background and current role?
TOM DONAHOE: Sure, I’ve spent 30 years on Wall Street in a variety of roles, including trading and portfolio management, building derivative trading units and sales staff, launching risk departments and leading risk-management efforts at firms on the buy and sell sides. I’ve held risk-leadership positions at Barclays Capital, where I served as COO of Market Risk and oversaw a full range of asset classes traded by an investment bank. Over the last five years I have been a chief risk officer in the hedge fund space, first at Angelo, Gordon & Co. LP, and then most recently at Aladdin Capital Holdings, LLC. With both firms the emphasis was on building out comprehensive risk-management infrastructures for strategies focused on fundamental credit analysis—including distressed debt, DIP financing, convertible bonds, bricks-and-mortar real estate and equity-structured finance vehicles, including CLO portfolios.
What is your insight on how to attain management buy-in related to risk management and compliance processes, especially when these processes have historically restricted the business in various ways? How do you accomplish your goals and gain a consensus opinion?
First and foremost you must appeal to the top decision-maker or makers, whether it’s the founder of the firm, the CEO, CIO or the board. You need to demonstrate added value. I view risk management as providing an independent perspective, while the various portfolio managers are, in a positive sense, like NASCAR drivers. The purpose of risk management is to provide the braking system for those drivers and ensure the essential support structure is in place. If risk management can provide an around-the-curve view to avoid surprises and accidents, then portfolio managers can go faster and indeed take more risk. Portfolio managers want to maximize the return of individual positions, but on a portfolio-wide basis they want to minimize the risk and variance of returns. Risk management has a strong role to play in helping achieve this shared goal.
Additionally, risk management must demonstrate to senior leaders that it can add value. Because the concerns of senior management change weekly, daily and even hourly, this is a way for risk managers to be responsive. We need to provide and interpret the information they want and lay out the likely outcomes. I would much rather provide senior management with critical information on a timely basis and come to the wrong conclusion than fail to provide them information that alerts them to a potential danger. Senior management makes the decision about whether to maintain a risk or not, but risk management should identify the key risk drivers, the likely interplay amongst these factors and the potential range of outcomes. Deferring ultimately to business judgment, a COO or CIO may want to take a known risk and reduce it, hedge it or take it off the table, and that’s the role for which they are being paid.
How important is the role of risk management in identifying future business opportunities and communicating those to senior management for their consideration?
This is absolutely an essential role for the CRO to play. Clearly risk management is charged with identifying the downside, but equally critical is helping the firm identify new opportunities. The CRO needs to provide oversight, and through this process they should also identify ways to increase top-line revenue growth and increase firm profitability. For example, when identifying industry sectors that may be especially vulnerable, risk management should also highlight those sectors that will likely outperform the broader market.
Risk managers often wear multiple hats, including that of strategic planning or product development. That is why at many firms, risk management oversees or drives the new-products review or commitments committees. By knowing the markets and the firm’s internal structures and capital resources, the risk manager is well positioned to provide a comprehensive analysis of a new product or new investment strategy. I have often analyzed possible acquisitions or divestitures of funds, investment vehicles or new-product initiatives, since risk management typically has entree across the firm and ready access to major data flows within a firm, and thus can estimate the marginal impact of new initiatives.
You mentioned how risk managers are able to help portfolio managers take additional risks within the investment criteria guidelines. Are there other ways risk managers can help portfolio managers achieve results?
The independent view is critically important. The risk manager is focused on the plumbing and infrastructure of the firm as well as the dynamics of the individual asset markets. We’re focused on the technical demand, buying and selling flows, identifying the major players in the market (especially those with strong or weak hands) and where the crowded trades might occur.
Portfolio managers are typically focused on strategy rather than on operational requirements and collateral flows. Risk management can help keep the portfolio manager out of trouble. I’ll provide two specific examples. Back during the crisis there was a mortgage trader with a portfolio that was deliberately unhedged. One day when he was on vacation it started to go sour pretty quickly. As CRO I immediately called him and alerted the firm as well. This enabled the firm to set up his collateral posting and other necessary operational steps well in advance of the actual collateral call. So the firm avoided the situation of a potential forced sale.
In another instance, we were able to correctly identify a pivotal point within a leveraged portfolio using a stress test which presented the range of outcomes with a market decline of 5 percent, 10 percent and 15 percent. Due to our analysis, management made the decision to immediately reduce risk in the portfolio. Approximately two weeks later, the market had continued to deteriorate and actually went through the particular stress level. Because we had liquefied some of the portfolio in advance, we didn’t have any forced sales and were able to post the collateral as needed.
The best decisions are based typically on answering a series of questions. For instance, if it’s a long-short portfolio, what are the consequences if we have a divergence in both directions? Are we truly market neutral? How much money do we really have on the table? We must look beyond the net exposures to the actual individual gross exposures. We need to really kick the tires and know the potential outcomes. What if relationships change? What if we have a divergence that has not occurred before? What are the possible outcomes based on the stress tests? And then the portfolio manager and CIO must decide, based on the resulting analysis, whether they want to guard against the outcome, hedge it, reduce the position or increase the position.
More generally, the crisis revealed that many firms failed to adequately manage their liquidity and their collateral. Stress testing enforces a risk discipline and focuses appropriate attention on where a portfolio might be vulnerable to shocks.
Are there other insights you could share about stress testing? What time horizons should organizations use when looking at stress tests, and what specific parameters should be tested?
First, the time horizon question. If you’re a hedge fund and you’re offering quarterly or monthly liquidity, the stress test should be structured so it tests shorter time periods than the actual liquidity horizon. By contrast, an insurance company might typically use a one-year time horizon. Your holding period also determines what you test. A shorter-term fund is focused typically more on spread volatility. For an insurance company the focus is typically more on default probability and loss-given default, since assets are often held for a multi-period horizon and paired against specific liabilities.
Many regulatory papers and books exist on the topic of stress testing. In my mind, there are four broad categories of stress tests as follows: (chart to be inserted)
You need to go into a portfolio line by line and look at what’s actually held in the it. For each of the positions or sectors, you must identify the contributing risk factors. If you can isolate these key risk factors, you can perform principal-components analysis. You can identify how much of the risk is coming from something linked to GDP, how much is linked to the price of copper or a particular commodity or how much is linked to a given index. Whatever the risk factor might be, you go through and find the commonality. Industry categories work well on a superficial level. You need to dig deep, determine the risk factors and then test those particular risk factors. GE offers a simple example of needing to refine your analysis. GE may be a large industrial company, but a major portion of its revenues and profit come from its many finance subsidiaries. Using its industry code would obscure some of its risk sensitivities, so this requires detailed analysis.
Each of the stress types mentioned above can serve a different purpose, but all are informative. You must understand the limitations of each approach and be especially cautious with using a historical look-back period, since different periods can provide widely different results. You also need to be especially alert for pro-cyclical bias. Ultimately, any of the stress methodologies is designed to trigger questions and should lead to a “deep dive” analysis into specific exposures. Forcing questions and creating a dialogue amongst decision-makers is the ultimate goal. You may be exposed to interest rates. Is it the level of interest rates, or is it the shape of the curve? If it’s exposure to commodities, is it specific commodities, calendar spreads or a full range of commodities? If you determine the proper risk factors and look at their historical correlation, you can better estimate the possible outcomes.
You can construct your own stress tests, but at least quarterly you should sit down with the chief economist or industry specialist and get their feedback about the key variables and their prognosis and outlook. In order to be useful, viable and prudential for the portfolio manager, investors and senior management, you have to be responsive to what’s going on in the market. A risk manager may have a series of historical stress tests used for reference and regularly maintained for reporting. However, on a dynamic basis, you must keep adding new scenario analyses in order to stay attuned to what’s happening in the market, the momentum that’s occurring and potential for regime and volatility changes.
Finally, some risk managers suffer from hubris and think they can do it alone. You must stay abreast of the constant changes in markets as well as in risk methodologies. Aaron Brown offers an accurate and direct industry indictment in his new book entitled “Red-Blooded Risk,” where he cautions, “Half of good risk management is just identifying and eliminating the bad risk management.”
Does a board’s risk committee play a role in ensuring that risk awareness is promulgated throughout the enterprise?
I’m not sure the risk committee is the proper platform to promote what people call the “tone at the top.” Leadership comes from an individual or a team like the CIO and CEO working together. They must believe in the focus and goals of risk management and live it. This means becoming personally involved in risk meetings and strategies, providing budgets for IT development and staffing support, and utilizing the analysis and insight from the risk-management unit. Risk needs to be involved in the strategy selection, compensation structure, commitments committee, IT planning, etc. in order to have the institutional recognition and stature that enables risk to interact collegially with all the critical areas of the firm. If you can disseminate that tone throughout the firm, you can go a long way towards putting together a viable, beneficial and productive risk-management structure and getting the risk ethos permeated throughout the firm.
To your question, the more critical role for the risk-management committee is to provide a platform for risk discussion and decision. Most people in a firm are aware of what’s going on in the market and what might be going on in many of the portfolios. When we can air a divergent set of views in a risk-committee setting, we’re basically concentrating all of that brainpower and all of the risk positions and portfolio information in a single locus. What should follow is an open discussion about what the risk profile looks like, where there’s concern or outright danger, and where the prospective opportunities lie. For there to be synergy, you need a broad swath of individuals coming together—the CIO, portfolio managers, the head of operations, etc. Hopefully, the committee decision is rarely a 9-0 or 8-1 vote. Instead there should be more dissension, because without a variety of opinions it becomes a rubber-stamp process.
Ideally, the risk manager will provide information in advance of the committee meeting and make it interesting. If no risk manager is present, you still want people to be able to read and understand the reports. The report has to be fully comprehensible within the four corners of the document itself: all the terms are defined, charts labeled, assumptions listed, conclusions and justifications highlighted. You want to synthesize the critical information on the first few pages using colors and graphs so it goes directly “into the bloodstream” of the reader and bypasses the brain. Then, provide all the supporting documentation for reference. Snapshots are critical, but tracking factors through time provides an essential context for analysis.
You want to generate discussion and have a variety of views, but not bitter controversy. I think the optimal situation is one where the chief risk officer has either a voice at the table or a vote at the table. He should not have the super-veto because that destroys collegiality. You want an active, participating CRO on the risk committee who has the requisite technical knowledge, broad experience and the force of personality to bring critical risk issues to the forefront. The CRO should force a conversation and a clear decision. When people leave the room, the mission forward should be clear, the steps should be actionable, the role of each person explicit and the entire team must be united behind achieving the shared goal. You want a team effort firmly fixed on success.
Risk management is constantly evolving. What do you see as some of the best practices today and in the future?
Firstly, prior to the crisis, market risk was largely viewed as a separate, independent risk strand, and certainly capital guidelines encouraged that segmentation. As a result of the crisis, firms are taking a more holistic view of risk. They are bundling the individual strands of market, credit and operational risk to provide a more comprehensive enterprise-wide view of the risks they’re facing. It allows them to look at the interplay between the various risks and knock-on effects.
A second best practice is the increased focus on doing “deep dive” reviews of special-purpose vehicles, structured-finance vehicles and other types of opaque investments people may consider. There should be a “deep dive” into the actual counterparties and the complexity of their organizational structure, the legal interrelationship and creditor rights. It’s been a watershed change. Instead of skin-deep review of a particular transaction or counterparty, there is now truly in-depth review.
A third would be more firms adopting a RAROC (Risk-Adjusted Return on Capital) approach. Instead of looking at performance devoid of the use of economic capital or the risk undertaken, people are focusing on performance attribution. Investors are often requesting detailed information prior to investing instead of simply relying on the track record and pedigree of the portfolio manager. The key questions are how much risk was undertaken, how much capital was used in order to achieve a given return, how is performance measured and how does it correlate to competing strategies?
Fourth is the recognition of the importance of the guardianship function (risk, compliance and operations), by both asset managers and investors. In the post-Madoff world, investors are demanding due-diligence review to be more than a “check the box” exercise. Investors want the ability to look at someone across the table and understand what the firm is doing and how the returns are being achieved, ensure the portfolio managers understand the markets where they’re involved and receive a full evaluation of the processes and systems that are in place.
Finally, an additional best practice is the tightening of valuation procedures and processes. I remember looking at prices from a particular external vendor during the recent crisis. They had failed to capture the market sell-off (in an opaque asset class) and update their prices. They fell behind the market by a few crucial days, and if it went undetected it could have caused material errors in NAV calculations. We took quick action to bring in additional external pricing sources and change our methodology to average the independent pricing. In retrospect we realized that even though an external-pricing vendor provides independence, it doesn’t necessarily provide reliability. Essentially we had put all our eggs in one basket using a single pricing vendor.
People are doing a better job of valuation, especially on the hedge fund side. A monthly or quarterly review of the valuation methodologies used for each asset class is an evolving best practice. This review should include risk, CFO’s staff, operations and other critical parties. Investors are demanding a better match of the asset profile with the liquidity profile of a particular fund. If side pockets are used, they are demanding that the asset go into the side pocket at the time of purchase and not at a later point in time. Finally, there is a focus on liquidity needs. People are doing more robust stress testing and examining the likely knock-on effects of one asset class spilling over to another, as we learned from spikes in correlation during the past crisis. In essence, practitioners are using multi-stage scenario analyses.
Regulation is affecting the entire financial industry, especially the asset management space. How do you view the risk-management role changing in light of the regulatory pressures?
The regulatory changes are coming in successive waves from a variety of sources. Basel bank capital requirements, new regulations under Dodd-Frank and a host of regulations from the SEC, New York Fed and CFTC. It might be more manageable if there was a single source or if we had more time to react to the various changes; however, regulators are making dramatic changes independently of each other. No one—either on the regulatory side or the business side—has really had time to fully analyze and measure the impact of all these regulations. Financial firms are often on a reactive basis because the final form of many regulations hasn’t come to pass.
Regulators are desperate for more data, but sadly data alone is not the talisman that they are seeking. Regulators want a closer relationship with the financial firms they’re regulating and a more open dialogue with each firm’s risk management and senior management. Regulators are driving changes in a major way and dramatically affecting the business model of many firms. They’re driving change, both through actual changes and through what financial firms anticipate they’re changing. On a competitive basis, firms are trying to get ahead of the changes to avoid being boxed out or labeled as latecomers in terms of their responsiveness to the regulators.
The changes I see require risk management within the firms to create new reports, gather more detailed and perhaps proprietary information and share it with the regulators on a near real-time basis. Many firms view this data provision requirement as intrusive and providing little added value to the regulators. Firms are rightly concerned about the potential loss of market share, profitability and, simply put, their financial freedom. Unfortunately the regulators are trying to address past crises. They’re often fighting the last battle, as opposed to putting a flexible reporting system into place and creating a dynamic interchange with the firms, especially the systemically important financial institutions, or SIFIs. Receiving data in isolation is a poor substitute for an informed dialogue between experienced regulators and skilled practitioners.
Do you see organizational changes taking place within asset management and investment management firms as a result of these regulations? If so, do you anticipate increases in staffing or changes in other focus areas?
There will definitely be added headcount, but I doubt we’ll see major organizational changes. As firms become more regulated, they have higher standards to satisfy, especially as related to fiduciary duty. They will be required to put systems, processes and people in place to keep pace and maintain compliance. Very specifically, in the compliance area I expect to see additional headcount and IT demands. Changes are not being driven solely by the regulators. Investors are also demanding a higher degree of transparency and view the risk function as absolutely necessary within a firm. They view risk as part of a guardianship function, an integral and internal safeguard that complements their own external due diligence and monitoring processes.
A higher cost will be involved as well. Optimistically, I hope some of the changes and reporting requirements will enable asset managers to have a more robust view of the actual risks they’re taking and the asset profile they have in place. We don’t know how successful those changes will be, but I believe there will be some benefit. I’ve always been a proponent of trying to provide regulators with as much information as appropriate. One fear is that the regulators will be deluged with too much information, often in various formats, and it may not prove to be that useful. When they finally gather everything together and analyze the data, it may involve a long lag time, and the next crisis may already have arrived in full force.
Are there ways that organizations can turn the need to meet these high regulatory standards into a competitive advantage for themselves?
It’s a possibility, and would of course be a very positive outcome. First and foremost, risk management is playing a more integral role, and that is completely beneficial for the firm. I view the risk management area as one that provides additional focus and independent perspective, basically serving the role of co-pilot. The portfolio managers in an asset-management firm are the original risk managers. Within the stipulated investment guidelines, they decide the composition of a portfolio. If they go beyond those bounds, compliance will alert them and force them back within their investment guidelines.
Risk management also guards against style drift. For example, with approved vehicles or instruments, they may be used in ways not originally envisioned. When there is sales material provided to the client or PowerPoint presentations, you must ensure you’re conforming to all the representations. The risk manager helps buttress the fiduciary-duty aspect of the portfolio manager.
Some of the best things risk management provides are independent focus and the ability to perform in-depth analysis. It provides warning to the portfolio manager about becoming overly concentrated, identifies potential challenges to collateral and liquidity and ferrets out crowded trades. I view the risk manager as the independent eyes and ears, providing information to the portfolio manager, but also reporting independently to the CFO, CEO or the board. Risk managers provide an essential, independent view and analysis of the actual contours of risk and potential investment outcomes that may occur. Certainly, improvements in methodology or comprehensiveness of risk focus will position a firm to perform better and be at a competitive advantage.
With the amount of data and systems involved, it could be challenging to choose between using internal resources and relying on third parties. How do you advise organizations to evaluate the balance between what they try to do themselves versus outsourcing?
This is the perennial quandary of build versus buy. Since every firm is uniquely situated there is no one solution. I would focus on the frequency and reliability of pricing availability and the amount of public data that is being manipulated. The more liquid and accessible the data is, the more likely that an off-the-shelf solution may be viable.
From the conceptual vantage point of an asset manager or a hedge fund, you have different pools of capital. You typically do not have the same investors in these various pools. Hence, there is a tendency to view exposures on an asset-pool-by-asset-pool basis, or a portfolio-by-portfolio basis. Until the last decade, there hasn’t been a sufficient focus on aggregating all those exposures across different pools of capital.
Now people are realizing that many of the homegrown applications they created weren’t made flexible enough to easily take into account changes in the market or in investor demands. It’s requiring them to bring in data aggregators and external parties to retrofit some of those applications, or potentially propose a different solution.
Very few firms can honestly say they have full, straight-through processing and complete, real-time reporting functionality that allows them to make adjustments on the fly and generate specialized reports. In some cases, it makes sense to stay lean and use an internal approach, for instance on distressed-debt investments. In many other cases, it makes sense to bring in an external vendor and actually build a resource or acquire a turnkey solution. One major benefit of outsourcing is that vendors have previously instituted this type of oversight and system in other firms, and the kinks have largely been worked out. Internally created systems, however, do have the advantage of ensuring that the critical know-how and expertise is retained inside the firm as a corporate asset.
There is a common saying, “May you live in interesting times.” We are certainly there. What lessons can organizations and risk managers learn through these interesting and difficult times in the marketplace?
Given the foibles of human nature perhaps we shall continue to make the same mistakes one crisis after another. The primary lesson is that constant vigilance is a fundamental precept to effective risk management. Certainly, we always knew there was a problem with leverage. Even today, some firms are still in the process of de-leveraging, and many residual assets need to be worked off the books. Leverage can be helpful, but too much leverage is potentially injurious to the health of a firm and could prove to be an existential threat.
In the hedge fund world, people have realized a lot of the alpha returns were anomalous. The returns they experienced were in fact leveraged beta returns. Although it’s a lesson we could have learned in the past, UBS showed us in 2011 that we still have operational risk, big time. The names may change, but it’s essentially the same types of losses—typically in the billions and accumulated over an extended period of time, often years. So again, we need additional focus on the operational risk controls. We really need to understand the processes on a continuous basis since they are indeed as dynamic as the markets themselves. If we go back three months after a process has been reviewed and documented, there is a high chance we’ll find the process has already changed in a material aspect.
Hopefully we learned that we had overconfidence and excessive reliance on models. The models were really dependent on historical time series and relationships. They were built for a calm-water environment (and were often pro-cyclical as a result) and weren’t necessarily meant for rogue waves or “white water” situations.
We also learned that transparency can be healthy, and investors are rightly demanding more transparency. Hedge funds seem willing to trade off more transparency instead of lowering fees. That’s a judgment call, but I think investors are looking for transparency first, and they will address the fee structure later. There’s also a realization that the government is now your co-pilot. It’s an unpredictable factor that will become omnipresent, at least for the foreseeable future. People need to be prepared for that. It adds enormous volatility and uncertainty to the future, but it’s a fact of life.
Additionally, the level of liquidity continues to erode in the markets. Firms have downsized, and volatility has increased. In general, people are taking smaller positions. Market-makers, when they make markets, are making them for smaller amounts. Most recently, we saw this during the past summer, especially in U.S. equity index trading.
The cost of transacting swaps will likely rise as well. Certainly, we are already seeing a bifurcation in pricing for swaps. If primarily generic swaps are centrally cleared, then more esoteric swaps will remain bilateral and there will be less opportunity for cross-netting amongst derivatives. It will probably decrease the attractiveness of derivatives in general. That’s a natural consequence and likely an intended goal of the legislation and regulations that are being imposed. I would point to centralized clearing parties as a potential new crisis sometime in the future, given the mutualized nature of the credit risk. The centralized clearing house is only as strong as its weakest links.
Tom Donahoe is the former Global Chief Risk Officer at Aladdin Capital Holdings LLC, an $11 billion hedge fund and CLO Manager with a focus on distressed debt and credit trading. Donahoe headed the Market Risk Committee and Valuation Committee and also oversaw risk in the affiliated US and UK Broker-Dealers.
Previously, Donahoe was the Chief Risk Officer at Angelo, Gordon & Co., a large multi-strategy hedge fund. He oversaw all aspects of risk across the firm, with then $17 billion AUM and a focus on distressed debt, DIP financing, real estate, convertibles, and RMBS/CMBS strategies. Donahoe spent six years with Barclays Capital as Risk Director for several product areas including equity derivatives, treasuries/agencies, commodities, FX, and Repo/money markets. He was also promoted to
Chief Operating Officer of Market Risk in New York.
Prior to Barclays Capital, Donahoe was a Portfolio Risk Director at Merrill Lynch and spent eight years at MetLife, where he started the Derivatives Trading Unit and helped launch MetLife’s first Corporate Risk Unit. Earlier in his career, Tom headed the Bankers Acceptance and internal treasury funding desks at a money center bank and was the Director of Trading and Sales for a large commodities trading firm based in Washington D.C., with assignments in Vienna and Zurich.
Donahoe holds a BS from Georgetown University, an MBA from Fordham University, an MA from Catholic University, and a JD from Pace University. He is an attorney and a member of the New York Bar. He served as an original PRMIA Director in New York. Donahoe has also authored papers on risk, including chapters
in various publications including the Professional Handbook of Risk Management.
David Samuels is Managing Director and Global Head of Risk Solutions and Analytics for S&P Capital IQ. In his role, Samuels is responsible for overseeing the Risk Solutions and Analytics operations globally, implementing expansion strategies, and managing the business to success.
Prior to joining S&P Capital IQ, Samuels was Chief Operating Officer and head of ERisk, an Oliver Wyman spinout which he helped sell to and integrate with the public financial software company, SunGard. Over four years at ERisk, he managed a global business that pioneered the commercialization of softwarebased offerings for economic capital and RAROC analysis aimed at improving an organization’s risk based decision making capabilities.
Prior to ERisk, Samuels spent four years as President and CEO of Zoologic Inc., a Bankers Trust company and the global leader in the risk and capital markets e-learning space. Prior to that, he was Vice President and Head of Global Field Operations at CATS Software, a provider of sophisticated risk management and trading software which he helped sell to and integrate with the public financial software company, Misys. Earlier in his career, Samuels was Vice President at SunGard Capital Markets and a Financial Analyst with Andersen Consulting.
Samuels holds a BS in finance and marketing from the University at Albany. Mr. Samuels writes and speaks frequently on the topics of Credit Risk and Economic Capital. Selected risk publications include: “Risk Appetite and the Pursuit of Strategic Advantage”, “Staying Two Steps Ahead in a Deteriorating Credit Environment,” and “Using ERM to Competitive Advantage.” Samuels is also active in various professional and nonprofit organizations.