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Consistent Decision Making

Consistent Decision Making. Robert Chambers AssetRisk Advisory Inc. Meaning of Consistency. Importance of Consistency. Strategy implementation Effectiveness Fairness. Judgment. This presentation is concerned with decisions where judgment (or discretion) is required.

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Consistent Decision Making

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  1. Consistent Decision Making Robert Chambers AssetRisk Advisory Inc.

  2. Meaning of Consistency CLEAR 2008 Annual Conference Anchorage, Alaska

  3. Importance of Consistency • Strategy implementation • Effectiveness • Fairness CLEAR 2008 Annual Conference Anchorage, Alaska

  4. Judgment • This presentation is concerned with decisions where judgment (or discretion) is required. • Not all decisions by a regulator require judgment. • The goal is to guide administrative discretion. CLEAR 2008 Annual Conference Anchorage, Alaska

  5. Major Causes of Inconsistency • Insufficient focus on what is important. • Silos that exist within the regulator. • Ineffective and out-of-date processes. • Inadequate training. • Overconfident licensee committees (self regulation). CLEAR 2008 Annual Conference Anchorage, Alaska

  6. Indicators of Inconsistency • Unpredictable outcomes. • Overturned decisions. • Allegations of unfairness. • Non-transparent processes. • Excessive criticism by the media. • Tolerance of the ‘likeable rogue’. CLEAR 2008 Annual Conference Anchorage, Alaska

  7. Top-Down Implementation CLEAR 2008 Annual Conference Anchorage, Alaska

  8. Intended Outcomes The definition of intended outcomes requires thought and planning before processes are designed to guide decision making. CLEAR 2008 Annual Conference Anchorage, Alaska

  9. Tools that Aid Consistency • Testing using control groups. • Risk prioritization worksheets. • Case assessment worksheets. • Decision trees. • Sound, documented processes. • Training. • Case management systems. CLEAR 2008 Annual Conference Anchorage, Alaska

  10. Modeling • Lack of reliable historical data is a problem in developing decision trees that rely on algorithms. • ‘Washing’ of historical data can be cost prohibitive and sometimes impossible if all relevant information was not collected originally. CLEAR 2008 Annual Conference Anchorage, Alaska

  11. Ongoing Monitoring • Management oversight by capable professionals who have bought into the process. • Periodic independent reviews of process and outcomes. CLEAR 2008 Annual Conference Anchorage, Alaska

  12. Case Study • The concern. • The response. CLEAR 2008 Annual Conference Anchorage, Alaska

  13. Case – Regulatory Focus CLEAR 2008 Annual Conference Anchorage, Alaska

  14. Case – Prioritization of Risks • Sample worksheet tool ‘A’. • Determine responsibility for control. • Likelihood. • Impact. CLEAR 2008 Annual Conference Anchorage, Alaska

  15. Case – Complaint Assessment • Sample worksheet tool ‘B’. • Evaluate every complaint/referral for regulatory significance. • Factors – plus and minus. • Quantitative vs. non-quantitative analysis. • Assess priority and resource allocation. CLEAR 2008 Annual Conference Anchorage, Alaska

  16. Conclusion Once consistency has been achieved within regulators, the next goal will be increasing consistency among regulators. CLEAR 2008 Annual Conference Anchorage, Alaska

  17. Contact Robert Chambers, LL.B., CPA, FCA AssetRisk Advisory Inc. 1402-30 Wellington Street East Toronto, Canada M5E 1S3 Direct (416) 304-0068 robert.chambers@assetrisk.ca CLEAR 2008 Annual Conference Anchorage, Alaska

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