I am not an opponent of experience and judgment, and I do believe that building a risk management system that is designed to be automatic is foolhardy. My point is that change is difficult at any institution or set of institutions.
It is even more difficult if the change is not consistent with the cultural and institutional environment and/or the skills of the management and staff. 5  BIS Review 68/2000  Difficulty with staff expertise is why the first steps for effective risk management probably should be the least technical and the ones with the best chance for payoff in the short run.