ICI and IDC Issue Paper on Board Oversight of Risk Management
The Investment Company Institute and the Independent Directors Council have issued a paper titled “Fund Board Oversight of Risk Management,” defining risk management and offering some best practices for fund boards. The paper asserts that boards are not responsible for managing risks but to serve as an oversight function particularly of the fund adviser’s risks. The paper defines risk to include investment risks and business operational risks. The paper argues that risk management responsibility ultimately lies in the business units responsible for the functions. The paper specifically notes that the Chief Compliance Officer is not the de facto Chief Risk Officer because the CCO focuses solely on compliance and regulatory risks, not the more expansive investment and business operational risks. The paper suggests several risk management tools (e.g. risk assessments, stress tests, and monitoring/escalation) and includes a long list of issues that Boards should discuss with management. The Board’s role in risk oversight must be disclosed in the fund’s registration statement.