Chief risk officer

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Glossary · Regulatory change

Chief risk officer

CROAlso called head of risk, head of the risk management function

Definition

A chief risk officer is the senior executive who leads a firm's independent risk management function. The CRO oversees how risks are identified, measured and reported, challenges business decisions against the board's risk appetite and gives the board an independent view of the firm's overall risk profile.

RISK APPETITELIMITSBREACH
Fig. 1 · Chief risk officer
CRD Article 76(5) · SM&CR SMF4 · EBA/GL/2021/05
Key rulesCRD Article 76(5) · SM&CR SMF4 · EBA/GL/2021/05
Applies toCredit institutions and investment firms in the EU
RegionsUK · EU · Global
01

How it works

The CRO sits in the second line of defence, separate from the business units that take risk. The role covers credit, market, liquidity, operational and model risk, sets limits within the board's risk appetite and reports breaches. The CRO usually reports to the chief executive and has direct access to the board risk committee.

EU rules require banks to have an independent head of risk who cannot be removed without prior approval of the management body. In the UK, the chief risk function is a senior manager function, so the holder is personally accountable for it. Supervisors meet CROs regularly and treat the role as a check on excessive risk taking.

Step 1Set appetitePropose risk appetite for board approval.
Step 2Set limitsTranslate appetite into limits for each business.
Step 3MonitorTrack exposures against limits and key indicators.
Step 4ReportEscalate breaches to the board risk committee.
02

The rules

EU · 26 June 2013CRD Article 76(5)Directive 2013/36/EU (Capital Requirements Directive), Article 76(5)

Requires an independent risk management function headed by an independent senior manager who cannot be removed without prior approval of the management body.

Credit institutions and investment firms in the EU
UK · 7 March 2016SM&CR SMF4Senior Managers and Certification Regime, SMF4 Chief Risk function

Makes the chief risk function a senior manager function requiring regulatory approval and a statement of responsibilities.

UK banks, building societies and PRA-designated investment firms
EU · 2 July 2021EBA/GL/2021/05EBA Guidelines on internal governance under Directive 2013/36/EU

Sets expectations for the head of the risk management function, including independence, access to the board and authority to challenge decisions.

Institutions subject to the Capital Requirements Directive
03

Common questions

Who does the chief risk officer report to?

Usually the chief executive, with direct access to the board risk committee. EU guidelines expect the head of risk to be able to raise concerns with the board directly, without going through business management.

Is a chief risk officer required by law?

EU rules require banks to have an independent head of the risk management function, and in the UK the chief risk function is a senior manager function needing regulatory approval. Smaller firms apply the rules proportionately.

How is a CRO different from a chief compliance officer?

The CRO oversees financial and non-financial risks across the firm, such as credit, market and operational risk. The chief compliance officer focuses on compliance with laws and rules. Some firms combine the roles.