Anonymous 6
Anonymous AnonymousOpposeIndividual
Summary: The commenter argues against removing succession planning from the Management component rating of the UFIRS rating system. They express concern that, especially for rural institutions, ignoring succession planning could lead to material financial risks and significant knowledge gaps.
While I agree that much of the proposed revisions to the UFIRS rating system are warranted, I disagree with the proposal to remove consideration of succession planning from the Management component rating. Particularly for institutions located in rural areas, where many financial institutions are headquartered, succession is a challenging component of operational risk, which, if left unchecked, could lead to material financial risks. The pool of qualified applicants available to some of these smaller institutions is limited and could create significant and/or prolonged knowledge gaps in the event of an emergency or other departure of key personnel.