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Senior Vice President, AP Risk In-Function Coordinator
January 10, 2021
Background: The new product approval (NPA) process is an integral part of Citi's Risk Management providing robust diligence, review and approval of new products and services as part of the end-to-end product lifecycle.Citi's NPA process considers both the diligence for approval and the requirements for on-going controls and management over the life of the product or service. Citi's NPA process helps to ensure that all new or modified products and services undergo a transparent, consistent, rigorous, documented and auditable review and approval process for the identification and evaluation of significant risks to Citi and its clients.Oversight of Citi's product approval committees (PACs) falls under the management of the Product Risk Governance.PACs offer an efficient forum for risk issues to be evaluated in the presence of the business and other control functions. PAC's consist of three committees organized by businesses being: New Product Approval Committee (NPAC) which covers the Institutional Clients Group (ICG), the Commercial Bank Product Approval Committee (ComPAC) which covers Citi Commercial Bank (CCB), the Consumer Product Approval Committee (CPAC) which covers the Global Consumer Bank (GCB. The firm's senior management and regulators require that there be an organized process to critically review all new proposed products and services for all business within Citi. The Product Risk Governance is part of the Risk Governance organization functioning within the Chief Operating Office of Independent Risk Management which is responsible for the design and implementation of firm-wide frameworks and practices that are integral and fundamental to Risk Management within Citi.The Risk Governance group is divided into 10 areas:1) Risk Frameworks & Risk Identification, 2) Risk Policies, 3) Product Risk Governance, 4) Risk Controls and Issue Management, 5) Regulatory Affairs, Governance Committees & Quality Assurance, 6) Strategic Analysis & Cross-Risk Initiatives, 7) Risk Learning and Development, 8) Program Governance, 9) Risk Management Reporting, and 10) Risk Headcount and Budget Management. Citi is currently under significant scrutiny from regulators globally around our new product approval process. The NPA process is being re-engineered globally to address concerns raised around the end-to-end process for new products/services ("Covered Initiatives") including development, initiative changes, risk assessment and ongoing review.These changes are largely driven by the need to make the process less subjective and more consistent with greater senior management oversight and governance, with reviews, reviewers and priorities being driven by the risk rating of the product against the Citi risk taxonomy. The new process is being rolled out and in structural terms, the new process includes:
Business pipeline reviews and Greenlight process: to apply the new Eligibility Criteria, confirm Businesssponsorship and prioritization.
Risk Assessment Review:a review of the Covered Initiative by all control functions and risk rating of the Covered Initiative by the Business, against the risk taxonomy, to be commented by the control functions and approved by risk category owners.
Committee Review:For any Covered Initiative rated high or medium risk there will be a committee review stage including senior members of core functions and subject matter experts and senior
Post Implementation Reviews: for 100% of initiatives that go through a committee review, within 6-12 months of execution of the Initiative.
To facilitate the new NPAC process, we have established a network of co-ordinators in business and functions to make the review and approval process more efficient.
In relation to each Covered Initiative:
Review content of each risk assessment / Covered Initiative Memo (CIM) to understand each proposal and ensure timely and correct completion of the Covered Initiative Assessment (CIA) section / PIR approvals based on guidelines.
Attend the Kick-Off meeting
Ensure that required additional information is provided to the relevant Contributor/Attester and liaise with additional Risk inputters/approvers.
Alert second stage Risk reviewers when relevant first stage reviewers have completed their review.
Escalate issues in Risk and / or NPAC team where required.
Co-ordinate with other Risk functions to ensure that the right people are involved, each risk assessment is reviewed in a timely and consistent manner and that risk ratings are reviewed and challenged appropriately.
Continually work with all Risk reviewers to ensure that understanding and application of the risk rating process is consistent and well thought through.
Provide guidance to Risk reviewers where risk rating assessments are unclear or a different view from the transaction team cannot be resolved.
Ensure that accelerated timelines for review of urgent proposals are agreed between transactors, Risk reviewers and the New Product Approvals team.
Co-ordinate Risk attendance at medium or high risk NPAC meetings to ensure seniority of attendees is maintained and that attendance is shared appropriately across the Risk function heads and their delegates.
Ensure Risk Category Owners understand their role and consistently apply the risk rating framework to confirm or challenge the Business risk rating.
Support data capture, management reporting and escalation for habitual non-compliance, including attending post mortem meetings during implementation phase.
Participate in post-implementation / look-back reviews and co-ordinate Risk function approvals.
Attend the working group sessions with NPAC and PMO teams to stay informed regarding anyprocess refinements or updates.
Produce regular management information to enable senior management oversight of Asia Pacific Risk engagement in the NPA process.
Maintain regular liaison with the NPA teams to keep up to date with process or policy changes and ensure that Asia Pacific Risk recommendations and requirements are considered.
Provide continuous education, understanding and consistency for Risk function reviewers and the broader Risk community to keep process and policy knowledge up to date.
Liaise with other control function and business co-ordinators to share best practice and develop process improvements to ensure established processes are underpinned with a strong controls environment.
Bachelor's Degree.Advanced Degree in business, finance, law or economics a plus.
10-12 years of relevant work experience
A well-developed product knowledge across Citi's businesses and products and the financial services industry in general.
Strong understanding of controls and Citi's control environment.
Experience and understanding of multiple Risk disciplines.
Experience of Citi's NPA process through contributions to reviews and / or attendance at NPAC meetings would be helpful.
Ability to quickly analyze a business proposal. Previous experience engaging with Risk, Compliance, Legal, Finance, and Operations is preferred.
Must be able to quickly create and deliver concise, informative executive summaries for senior management.Must be comfortable presenting such analyses to senior management and advocating in favor of a point of view.
Exceptional communication skills, including well-developed verbal and written presentation skills, proven ability to distil complex ideas into simple stories and strong interpersonal skills while working across multiple geographies, businesses and functions.
Good audit instincts and ability to apply independent judgment to historical business practices.Strong attention to detail.
Excellent organizational skills, ability to multi-task. Able to manage multiple proposals concurrently that are often different in subject and urgency.
Good team player while working independently to bring tasks to completion.
Ability and willingness to challenge the status quo.
A self-starter with the ability to independently manage work and drive multiple deliverables concurrently.
An undergraduate degree is required.An MBA, CPA or CFA is preferred.
Exceptional candidates who do not meet these criteria may be considered for the role provided they have the necessary skills and experience.Product knowledge over a broad set of asset classes and transactions (e.g. Equities, Commodities, FX, Rates, Structured Products, Private Equity, eCommerce, Cash Management, Trade Finance, Custodial Services etc.). Experience in ICG products is preferred. Primary Location: Hong Kong Grade/Level: C14 (Senior Vice President)
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