UBS Trust Company, N.A. is a limited purpose national bank that is chartered and supervised by the Office of the Comptroller of the Currency (OCC). The Trust Company provides corporate trustee services for personal trust accounts, generally for high net worth and ultra high net worth individuals and families.
The CRO is responsible for identifying, measuring, monitoring and reporting on risks independently of the business or Operational Management. The CRO approves risk exposures in accordance with delegated risk control authorities and monitors and challenges the Trust Company's risk-taking activities.
The CRO is responsible for the effective implementation of the risk control governance framework within the Trust Company to meet the requirements of the Trust Company Board of Directors (Board); the Trust Company Chief Executive Officer (CEO); the CRO of the UBS business division of which the trust company is a part - UBS Wealth Management Americas (WMA); the applicable policies, standards, practices, and authorities established by the UBS Group Risk organization; applicable OCC legal and regulatory requirements; and applicable OCC guidelines, handbooks and similar publications.
The CRO has access to the Board without impediment, and will report to the Board on a regular basis.
The CRO brings together the resources of the Group Risk organization as applicable to ensure that risk controls established within the entity leverage best practices, and meet the requirements established by the Group Risk organization.
In addition to the above responsibilities and authorities, the CRO is responsible for the following matters:
The CRO has an independent reporting line - reporting ultimately to the UBS Group chief Risk Officer through the Wealth Management Americas independent risk organization and WMA CRO. The Trust Company CRO has an additional reporting line to the CEO for the Trust Company and will report regularly, in person basis to the Board. The reporting line to the WMA CRO shall prevail over the additional reporting line to the business line CEO. In the case of a disagreement between the CEO and CRO, the issue shall be promptly escalated to the CRO Wealth Management Americas and the Board.
- Defining the strategy, the goals and the organizational structure of the risk control function
- Ensuring that the Trust Company's approach to risk control is consistent with regulatory requirements, market practice, and UBS Group standards
- Documenting the approach for the management of risk in the Trust Company, clearly identifying the inherent risks of the business, along with providing clarity on the control structures and management responsibilities for the performance of controls
- Meeting the needs of the OCC for assessment of risk as described in the Large Bank Supervision - Comptrollers Handbook - January 2010 including reporting and assessment of risk according to the eight defined categories (Credit; Interest Rate; Liquidity; Price; Operational; Compliance; Strategic and Reputation)
- Proactive monitoring of risk exposures in conformity with the risk principles, profile, appetite and limits approved by the Board
- Independently Measuring and aggregating all material risks
- Providing regular reports to the Board, the Risk Committee and Senior Management in a manner and format that allows them to clearly understand the risks being assumed by the Trust Company
- Exercising Risk Control authority in accordance with the Risk Authorities, including decisions on exceptions to Group policy, and ensuring appropriate evaluation of risk (including reputation risk) and reward in risk decisions
- Interacting with regulatory authorities on risk management and control issues, in close coordination with the Compliance, and Audit where relevant
- Chairing Risk Control Committee meetings, including overseeing the status of any remediation programs necessary to address control issues
- Educating the business on risk policies, processes and applications as needed and promoting a strong fiduciary risk management culture
- Reviewing Trust Company New Business Initiatives & Outsourcing Business Initiatives, and approving (including with conditions) or not approving those initiatives
- Partnering closely with the Board and CEO to ensure that business growth plans and initiatives are supported by a strong and effective risk control structure
- Partnering closely with the other control functions supporting the Trust Company to ensure that Operational controls, and the governance process to oversee these, are effective.
- Establishing the processes and controls to assess the accuracy of any risk information or analysis provided by business lines in order to be in a position to offer objective reporting to the Board, the Risk Committee and Senior Management.
These responsibilities arise from the following Group UBS documents:
- The Group Risk Management and Control Principles 1-P-000013 defining Group-wide key principles for the management and control of primary, operational, funding and business risks.
- The Corporate Center Business Regulations 9-C-000009 and the Group Chief Risk Officer (GCRO) - Role Profiles 9-S-00321 which describe the main roles and responsibilities of the GCRO and Risk Control Functions respectively.
- The Operational Risk Framework (ORF) 1-P-000017 describing the general requirements for the management and control of operational risk at UBS.
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