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COMMERZBANK AKTIENGESELLSCHAFT

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74<br />

Commerzbank AG<br />

Operational risk<br />

Operational risk (OpRisk) at Commerzbank is based on the German Solvency Regulation and<br />

is defined as the risk of loss resulting from the inadequacy or failure of internal processes<br />

and systems, people or from external events. This definition includes legal risks; it does not<br />

cover reputational risks or strategic risks.<br />

OpRisk management<br />

The management and limitation of operational risks differs systematically from limiting<br />

credit and market risk, since the relevant management units are not made up of individual<br />

clients or positions but internal processes. For this type of risk we focus on anticipatory<br />

management by the segments and cross-sectional units based on an overarching risk strategy<br />

for operational risks and their specific aspects.<br />

Areas for action and quantitative guidelines for the risk strategy are defined at Group level<br />

and segment level. Management issues are regularly examined in meetings of the Group and<br />

segment OpRisk committees.<br />

The identification of intra-risk concentrations is carried out via the evaluation of the<br />

Group’s OpRisk profile. This primarily involves analysis of incurred loss events (realised losses<br />

and provisions), the parameters derived from the capital model (EL, RWA and economically<br />

required capital) and forward-looking scenarios in particular by type of event category and<br />

incurring unit, the results of which are reported to the OpRisk committees of the Group.<br />

Management of the Commerzbank Group’s legal risks on a worldwide basis is handled by<br />

Group Legal. One of the core functions of Group Legal is to recognise potential losses from<br />

legal risks at an early stage, to propose solutions for minimising, limiting or avoiding such<br />

risks and to establish the necessary provisions.<br />

OpRisk developments<br />

We continued to pursue our objective of improving the Group OpRisk profile in the year<br />

under review. The main priority here was to optimise our methods and processes, in particular<br />

the ongoing development of the early warning system.<br />

This was also reflected in the decrease in the charge for operational risks. The total charge<br />

to Commerzbank in 2011 for OpRisk events (losses plus changes in provisions for operational<br />

risks recognised in equity and ongoing litigation) was €250m (previous year: €274m).

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