3LoD Creates Red Tape

The last few weeks I have been blogging about Risk Leadership. I have covered why risk management has failed in many organisationswhat the risk function should look like in the next decade and the leadership required from the risk function in the next decade

While on the surface the Three Lines of Defence Model (3LoD) model seems like a good idea, it has underlying problems for the risk industry. I have been writing about the negative impact of the approach for years and years. I note that the Institute of Internal Auditors has acknowledged there has been criticism of the model and has prepared a discussion paper and is currently running a survey about the model.

One thing that went against the model is that regulators picked up on it. For very good reasons. The result, a whole lot of red tape.

Check out the Industry Dynamics figure below. You can see that for all three players, the regulators, the risk function and the business itself, they all want the same thing. They want good customer outcomes¹. That is where the similarities end.

What do regulators want? They want to be an effective regulator. They don’t want organisations failing on their watch and they don’t want poor behaviour by organisations they regulate. 

What does the risk function want? It wants to be heard and to become a trusted adviser to the business.

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¹Albeit some business leaders allow short-term profit making to take precedence over customer outcomes as evidenced from enquiries into the financial sector.

And the business? The leaders of the business want the organisation to be an industry leader. In the for-profit sector, that means great returns for shareholders in a financially and environmentally sustainable fashion while being socially responsible. In the not-for-profit and public sectors, it means impact while maintaining integrity with all key stakeholders. Whether that be through sound fiscal, ethical or any other area of management.

In order to achieve their goals, the regulator demands red tape. The risk and compliance functions duly answer the call and create red tape. And the business? Well they spend the rest of the time trying to avoid red tape. That is, to avoid processes they see as non-value adding.

The result? Refer to my blog about covered why risk management has failed in many organisations. Not good.

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Bryan Whitefield works with strategic leaders across all sectors to help organisations harness uncertainty – uncertainty is the strategic leader’s best friend. He is the author of DECIDE: How to Manage the Risk in Your Decision Making and Winning Conversations: How to turn red tape into blue ribbon. He is the designer of the Risk Culture: Build Your Tribe of Advocates Program for support functions and the Persuasive Adviser Program for internal advisers. Both can be booked individually or in-house. For more information about Bryan, please click here.

www.bryanwhitefield.com

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Bryan is a management consultant operating since 2001, specialising in risk-based decision making and influencing decision makers, born from his more than twenty years of facilitating executive and board workshops.

Bryan’s experience as a risk practitioner includes the design and implementation of risk management programs for more than 150 organisations across the public, private and not-for-profit sectors.

Bryan is the author of Risky Business : How Successful Organisations Embrace Uncertainty; Persuasive Advising : How to Turn Red Tape into Blue Ribbon, and Team Think : Unlock the Power of the Collective Mind [to be published in 2022].

He is licenced by the RMIA as a Certified Chief Risk Officer (CCRO) and is the designer and facilitator of their flagship Enterprise Risk Course since 2019.

<a href="http://www.bryanwhitefield.com">www.bryanwhitefield.com</a>

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