
1400
0
350
NUMBER
OF
COMPANIES
700
1050
1995 1996 1997 1998 1999 2000 2001
188 Operational Risk Control
䊏 Some regulators like the Fed, OCC, and FDIC, have their own examiners.
䊏 Others, like the FSA, are not resourced to do this, and they depend on the audit by
chartered accountants.
In connection to this last point, there is a question of crossborder consistency. This,
too, should be reflected in, and compensated by, the design of the scoreboard. To
contribute to Pillar 3, external auditors must themselves be disciplined and they
should use a normalized form of reporting on operational risk capital allocation by
the entities they audit.
9.3 The use of templates ...