Addis Ababa
February 22, 2015
Project for the Amalgamation of CBB with CBE: Risk Management Team 2016
Acronym
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Project for the Amalgamation of CBB with CBE: Risk Management Team 2016
Contents
1. Introduction ................................................................................................................................... 4
2. Objectives....................................................................................................................................... 5
3. Scope ............................................................................................................................................... 5
4.8 Orientation on CBE Strategies & Change Management Technical Team .......................... 37
5. Concluding Remarks................................................................................................................... 41
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1. Introduction
The recent government decision for the eventual takeover of the Construction and
Business Bank by the CBE and it's ultimate liquidation is been carried out by forming a
consolidation project with a clearly defined governance structure and a tight time
schedule to complete the task. A clean consolidation of the CBB with CBE in accordance
with acceptable accounting standards and incompliance with applicable laws and
regulations required to be observed under such circumstances while institutional memory
and traceblity and integrity of records are ensured iz a task which requires expert
planning, knowledge and commitment from all project personnel called up on to do the
job. Furthermore; a soft issue of integrating the two banks human resource is another
dimension which requires far more due deligence and careful planning than the rest of
the consolidation tasks of the project.
One of the planned activities and hence deliverables of the Risk Management Team of
this project is to assess the project risk implications of the plan of actions drawn by the
In this report; we have presented our observations of which some may prove to be
highly important while the others rudementary and with tolerable risk implications on
the successful achievement of the project objectives. This is partly because risk implication
of project planning issues are not measured to determine the severity or otherwise of
risk implications as there are no methodologies adopted by CBE which is the ultimate
institution regarding which we intend to protect from project risk eventualities.
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2. Objectives
The objective of this risk assessment report is to identify project planning related risk
exposures and come up with risk mitigation proposals to be adopted by the project
office and project teams while handling the takeover and; as appropriate, by the CBE
during and after the takeover of CBB in order to achieve the amalgamation projects
ultimate objective of a smooth, reliable and verifiable consolidation of the two
institutions assets, liabilities, contingencies and their human resources and other intangible
resources.
3. Scope
The scope of this risk assessment covers the nine project technical teams plan of action
submitted to the project office and subsequently tabled to the steering teams approval. The
only action plan which is not reviewed in a bid to identify project planning risk implication
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identification and measurement methodologies are not adopted as the time required to do
that will compromise the relevance of the risk assessment report in addition to the absence
of identification and measurement methodologies for this kind of risk in both CBE and CBB
risk management programs.
The Finance Team Action Plan review resulted the below fourteen Project Risk areas
which we believe should be recognized and for which mitigation mechanisms be
instituted.
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handled and keep updated. It has also been the practice of CBB to use a single
saving account to entertain various customers who are required by
municipalities to block certain amount mostly in association with housing and
land lease arrangements. If that practice remains to this day such account
balances need to be reconciled and keep updated just like and payable
account. The six week time allotted for reconciliation of suspense accounts by
the finance team appears to be at odds with the depth of the task and the
verifiability of the manner such accounts are going to be handed over to CBE
designated branch or head office management. The risk implication can be
extension of project conclusion or heightened post-merger operational risks to
CBE.
Mitigation: our recommendation is to look in to this task through to the end
which is the final verifiable handover to CBE and design a strategy how to go
through this and while doing that to determine the extension time requirement
and/or HR requirement right away.
b. The fixed asset tagging may depend the ultimate location of the fixed assets as
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Mitigation: To count and balance fixed asset vis-a-vis fixed asset detailed
record and to verify that with CBB GL fixed asset records and to synchronize
the tagging task with the decisions on the fate of branch rationalization output
and dvisions to be made based on a proposal to retain or dispose particular
fixed assets the responsibility of which the finance team may assume
ccapitalizing on its fixed assets inventory sub team's observations while
conducting its count. The actual coding of fixed assets as per CBE coding
structure can be handled after the merger provided that by whom, how,
within what time frame, etc. is put forth in an approved action plan.
c. Handing and taking over of fixed assets and relevant documents are not
included as the teams responsibilities: the responsiblity to carry out and the
procedure to be adopted upon actual fixed asset handing and taking over
between takingover CBE supervisor, manager, director, etc. and handingover
CBB PSM Process, the rest of CBB Processes including Executive Management
Offices and Branches are not included in this or any of the rest of the teams'
activities in thier action plan. This will lead to a probable disorganized and
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and credit products may have distinct features which may require CBE to
handle them by creating separate products other than those it already has.
That may require separate category definition in T24. Hence either new line
definitions in CBE GL and summery and detail financial statements already
defined in T24 and other report processing applications it is using currently
may be required or existing lines may require amendments to accommodate
the new categories defined. Obviously; if there are multiple such cases for
some the former may be appropriate and the latter may be appropriate for the
rest of them. Unless; these issues are entertained in the planning and the
manner the decision to such effect is going to be made and executed are
preplanned the project completion task may be dragged and hence the
consolidation date can be pushed forward unnecessarily. If such considerations
are not entertained appropriately it may result blending products which have
distinctly different characters. An example can be the special saving product
CBB has in which CBB and the depositors under this scheme have distinct
contractual commitments for both of them to be abide by.
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The consolidation process will not address clear and down to earth take over
which will lead to probable book keeping problems sfter the conclusion of the
merger with financial loss implications.
Mitigation: Consolidated Branch financial reports and consolidated district
reports should be verified and properly handed over accordingly.
h. The pooling method of consolidation will undermine CBEs financial benefits
out of the consolidation process and may lead to qualified or adverse audit
opinion: while technically IFRS complaint; the takeover can be handled by
revaluing CBB's Assets to their respective fair values which would; taking a
rather wild estimate, may give CBE the opportunity to increase its capital by
about ETB 1 billion more than what will the inctease in CBE's capital will be
under the recommended and adopted pooling of interest method.
Mitigation:
i. The stock reconciliation may take an extend time which may compromise the
consolidation finalization scheduled date: the experience of CBB in stock
reconsilation may suggest that taking a reconsiled stock records with that of
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l. The Head offices Accounts and documentations Takeover by the Team and
afterwards Handing over to the Head Office Finance Function or
intermediating the takeover of accounts and documents by CBEs Head Office
Finance Function is not covered as an activity by the Team: if the balances of
accounts in the books of records of CBB plus all relevant documents are going
to be taken over by the finance team (i.e. of course including those records at
the CATS Center); the procedure, formats to be used to handle the handover
plus the documentation for future verifiablity should be among those activities
the team needs to take care of. To some extent the team is anticipating to take
care of taking over accounts but neither that completely covers what is
expected to be taken over nor does it anticipate the handing over of what it
has taken over permanently in a permanently verifiable manner to authorized
CBE management.
Mitigation: The Head offices Accounts and documentations Takeover from
the team and/or the FM Process of CBB should be incorporated in the team's
action plan.
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Project costs which are costs accounted the bank's investment in designing and
building standard DC & DRC procuring all necessary equipments, servers,
accessories, etc. and T24 CBS aquistion and implementation costs. CBE needs
to determine which costs in this asset account have future economic value and
which represent a sunk cost of no use for CBE and immediate post merger
write off decision recomendation can be formed, tabled for steering team
approval and implemented. Otherwise; the consolidated financial position
may not be the fair representation of CBE'S financial position after the
takeover.
Mitigation: distinguish between the costs of economic value and the costs
which are not and table a clear proposal for endorsement.
The following three Project Risk Implications have come to our attention while we
a. The Teams Objective are not complete which means project objectives may
not be clearly understood: Classifying loans and advances as per CBE Portfolio
classification, consolidating loans and verifying consolidated credit portfolio
after migration, resolving interest rate variations, follow up and update data
until the final migration, plan for handing over of loan account balances vis--
vis the loan files and security documentation to the appropriate CBE Credit
Center and actually doing it and finally the implementation of approved
consolidation plan are not among the objectives listed in the action plan.
These objectives which should have been translated in to planned activities
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may undermine the project timely completion and/or increase the possibility
of operational and credit risks of CBE after the merger.
Mitigation: the recommended actions are obviously to redefine the teams
objective and hence to include the above tasks as planned activities of the
team and evaluate the time and human resource requirement to handle the
job accordingly.
b. There is no cut of date in the plan and update procedure afterwards: the
action plan does not state a cut of date for its verification and taking over
activities. Thus the update procedure if and when it is adopted will have no
clear reference as to from which date updates are handled up to the conclusion
of the consolidation. This will have adverse balance verification implication
against the balances reported in the GL which will as well affect the finance
and data migration tasks.
Mitigation: clearly define a cut of date for its activities.
c. The loans approved but not disbursed as of the cut of date, loan approvals
and disbursements and disbursements and write offs of undrawn balances in
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operational and credit risks to CBE after the merger. The other alternative
course of action to correct this planning inadequacy is to extend the projects
original implementation period.
Mitigation: to correct the plan to account for loans approved but not
disbursed at the cut of date and subsequent updates to account for
disbursements made to these or other loans with partial undrawn balances at
the cut of date, undrawn balance write offs and new loans and disbursements
made both in the interim period until the final consolidation date.
Furthermore; the verifications of documents purporting approval of loans,
disbursements made and undrown balance written offs should be planned to
be done against the data captured in the banks CBS.
d. A course of action after merger if loans approved are not disbursed at all until
the final consolidation date: loan approvals made during the interim period; if
for any reason there disbursement is not done in time before the consolidation
process is over, may merit to be tabled for CBE management for re-evaluation
of the approvals to ensure their conformity to its credit policies and
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Mitigation: in the event CBEs own collateral and limit data have reasonable
degree of integrity; collateral and limit information captured in CBBs CBS
should be among the tasks listed in the teams action plan.
f. The review result should include or should be followed by a course of action
which can be executed during the interim period or; if that is not
possible/applicable, after the merger so that the center taking over will take
over along with sets of courses of actions approved by the steering team: this
is an important aspect of the merger process which helps the project to
eliminate probable financial loss as a result of the manner the merger process is
handled by the project. For instance; if a security contract registration or
collateral insurance policy requires a renewal it can be specified as an interim
period action or a post-merger course of action specification for the center
taking over the loan is required to proceed with.
Mitigation: to plan course of action to be disclosed in the handing and taking
over document design and to capture required actions and to keep them
updated in the interim period is recommended. Obviously; the actions needed
The Trade Service Team Action Plan and its relationship with the rest of the other eight
teams' action plans have also important aspects the project needs to look in to so that
the project is concluded successfully and within the planned time period. These identified
project risk exposures are discussed as follows.
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g. The teams deliverables are not conclusive enough: The last deliverable in the
deliverables section of the action plan is a testing report which is not clear as
to its content. On the other hand; if the team is taking over files and balances
and statuses of active LCs, CADs, etc. from CBB TS process and for some of its
other responsibilities from CBBs CATs process the team should have
considered taking over report as one of its deliverables. Furthermore; pre and
post data migration data verification report and subsequent handing over to
appropriate CBE work unit of accounts and active commitments and
documents the TS Team has been handling should have also been mentioned
among its deliverables. It is reasonable to assume that missing deliverables can
either threaten projects takeover activities accountability and verifiability or
hinder the project from finalizing its consolidation responsibility within the
planned time schedule.
Mitigation: pre and post migration data verification report; if the team is
planning to takeover TS outstanding operations, balances, documents etc.
from CBB and handing them to CBE pertinent work units, the teams taking
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Mitigation: to plan for and incorporate the updating activity in the plan of
action of the team is the straight forward recommendation to handle this risk.
i. The Gantt chart presentation of the action plan states that the last activity of
the plan which is to be done from March 16 to 31 is preparation of a
consolidation proposal: the consolidation plan is not the end by itself.
Considering it as the end result activities after the proposal not to be planned
in advance and hence result the takeover successful completion in doubt.
Mitigation: to plan the implementation activities as per the consolidation
proposal in the teams action plan is recommended.
The following five Project Risk Implications are identified while we review the action
plan of the Projects Legal Technical Team.
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the manner of handing over and actually handing over cases and files/folders
to concerned CBE Process, Directorate, Team, District or whatever work unit
as appropriate and applicable is necessary as the teams takeover of
active/inactive cases and legal advice files is not the end of the story in the
amalgamation process as implied by the teams action plan.
Mitigation: Plan revision to accommodate the activities missing from the
teams plan of action is recommended.
d. Proposal for required actions on contracts and Investments to be taken in the
interim period (i.e. prior to conclusion of the amalgamation process) and after
the consolidation is done for those issues identified to require resolution/action
along with defined responsible party for action and mechanism for follow-up
should have been anticipated in the plan: actions which may include money
transfer, correspondent bank accounts, investments, IT contracts, etc. should
be part of the activities and Steering Team approved course of actions should
be monitored and statuses should be followed through until cases are closed
by the team and weekly status report should be tabled to the project office
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known down to the exact cents when and only when the consolidation
process is done and verified which may be the last couple of hours of the final
day of the consolidation. This may present a challenge to get the right amount
of capital increase at the right time for the endorsement of the regulation by
the council of ministers.
Mitigation: Two distinct strategies can be deployed to avoid and perhaps
maximize the capital increment opportunities for CBE. The first is to conclude
the consolidation on the first day of the next accounting year and the other is
to back date the council of ministers two regulations while they are actually
presented for endorsement a day or couple of days after the actual date of
consolidation.
a. Exclusion of CBE Branches taking over CBB Branches from the Branch Grading
Exercise: Branch Grading is considered only for CBB Branches which will
continue operating but not CBE Branches which will take over CBB Branches in
the merger (whether they remain at their current location or move to CBB
Branch Office). This may cause employee job satisfaction and in engagement
to fall.
Mitigation: To extend branch grading to CBE branches which will take over
CBB Branches a result of the takeover is the logical course of action.
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and get approval will help to ensure convenience for decision making, allow
other teams to proceed because financial consolidation may not depend on
branch grading issues. Thus; bundling deliverables as a single output has its
own adverse effect on the success of the project to meet its scheduled
conclusion date.
Mitigation: Recommendation for closure of CBB Branches by transferring their
records to specifically named CBE Branches can be attempted as a first
deliverable of the team instead of handling it together with Branch Grading
Recommendation which may take time to do the analysis before reaching
grading recommendations.
e. Takeover of rental contracts, files, Cash, etc. and Office Standardization in
relation to CBB Branches to continue operation as CBB Operation are not
included in the Teams Action Plan: Branch Retention requires updating
concerned Processes/Districts to takeover rental contract issues, office
standardization issues, active files, active customer files, security printings,
archive files, etc. which is left unmentioned in this or the rest of the teams
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Mitigaton: to determine whether there are such possibilities and if there are
reasonable predictions of such circumstances of reasonable volume then to
come up with a work around solution are the recommended courses of
actions.
f. Migration of Standing Instructions involvement and verification of branches
vis-a-vis credit and finance teams of the project: this is an important task which
may compromise the reliability of the migration process with probably serious
financial quencquences unless verification is done vis-a-vis valid
documentations.
Mitigaton: we recommend planning and executing validity of standing
instructions before and after the migration of standing instructions.
g. Data Migration Strategy Document preparation and Data mapping activities
are planned to require 5 days and 4 days, respectively: this critical and detailed
and on some of the issues require more intuitive thinking are undermined as
can be inferred from the number of days assigned to do these jobs.
Mitigaton: it is advisable to consider the depth and complexity of these
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on the fate of the Head Office Building while the same may not be true for the
DRC site at Bishoftu it's fate as a DRC is as uncertain as that of the the DC.
Furthermore; the infrastructure redesign may come up with alternatives for the
steering team's decision regarding these two sites. Unless the level of
investment and its future usescare apperciated by decision makers valuable
resources of CBE after the merger and of course our poor nation may lay
waste.
Mitigaton: The team should consider preparation of a proposal for alternative
uses of CBB's DR & DRC.
j. Taking over backup data of earlier CBB legacy systems (i.e. SmartBank and
Ownsys legacy systems) after ascertaining the Integrity & Completeness of Back
up data is not included in the IT Team Plan: CBB has carried out two
automation transitions within almost the last five years. That means historical
transaction files are av as ikabke only in the backups of these legacy systems. In
order to entertain customers' and third parties' inquires; that is of course in
addition to CBE itself, these backups are going to be called to service. If the
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n. The go live plan is beyond March 31st (i.e. it is in the middle of April) which is
a rather difficult date for handling mergers: the interest update issue is very
convenient if the final migration is done after COB is done at month end (even
better if it is done on June 30th closing) as the interest to be governing
accounts (except special saving accounts) is most probably that of CBEs.
Mitigation: considering the migration simulstion issues and the ultimate
possible convince June 30th offers; it is best to simulate the consolidation up
untill then and finalize it right after year end closing.
o. Creation of users in T24 should be identified as one of the activities the IT
Team should have included in its action plan as part of the go live preparation
after the verification of the consolidation: T24 user creation and acess right
definition are among the major tasks not covered on the IT Team plan of
action. This may affect successful post merger commencement of operations
with customer dI satisfaction implications.
Mitigation: Creation of Ex-CBB users in CBE's T24 CBS should be handled prior
to the go live of operations after the consolidation.
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The Employee Assessment and Placement Team Action Plan review resulted the below
six Project Risk Implications which we believe should be recognized and mitigation
mechanisms be instituted as soon as possible.
a. Possible Mistakes in capturing CBB employees' Profile: CBB Employees are not
invited to confirm their profile and hence errors and inappropriate placement
which may affect the achievement of CBE Objectives are possible
consequences. Given the expectation of employees in trusting HR to capture
their professional experience and education and training profile and given that
experience dictates reliability and completeness of HR records are of
questionable integrity; employees of CBB may doubt correctness and
completeness of their profile captured by the team. As a result; they may
develop dissatisfaction on their new assignment.
Mitigation: Allow CBB Staff to verify and consent on the correctness of his/her
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placement job of nearly 20 hundred CBB staff in various CBE positions at its
Home Office, Districts and Branches may result a rushed decision making
which may ultimately result inappropriate placement decisions which may be
in the best interest of the bank (i.e. CBE) or the assigned staff of the to be
dissolved CBB or both.
Mitigation: Placement should be seriously executed by giving appropriate
length of time for execution.
d. There is no specified Involvement of the Steering Team in the Placement
Decision or Handling of Complaints by CBB staff regarding Placement
Decisions may result employee dissatisfaction and loss of competent human
resource: Only the Project Director is involved apart from the Projects HR
Team of course in the placement decisions and the Steering Team has no
involvement in the placement task. CBB staff may doubt the whole placement
process and result loss of competent employees.
Mitigation: allow involvement of the steering team on the placement process.
e. There is no adequate time to handle required trainings prior to final
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The following three Project Risk Implications have come to our attention while we
review the action plan of Orientation on CBE Strategies & Change Management Team.
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The following three Project Risk Implications are identified while we review the action
plan of Communication and Awareness Creation Team vis--vis the rest of the project
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5. Concluding Remarks
The following are few concluding remarks drawn based on our observation on the entire
project set up and planning activities we would like to highlight as possible causes for
one or more project risk implications that we have discussed in the main body of this
report.
a. The project office has arranged for the teams to discuss and workout
integration issues among themseleves. While that is a commendable effort
excersised in a bid to make sure project objectives will be achieved within the
specified time period; it would have been even better if project plan
consolidation is attempted by covering all the detail tasks, determine input
output relationships among activities, clearly defining responsiblities etc. The
implication of the absence of thus attempt can be the cause of some of the risk
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Finalization of the amalgamation of CBB with CBE at the end of the third quarter of
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