Audit

---------------------- Forwarded by Vince J Kaminski/HOU/ECT on 12/30/99
04:31 PM ---------------------------

VKaminski@aol.com on 10/03/99 04:25:26 PM
To: Vince J Kaminski/HOU/ECT@ECT
cc:
Subject: Audit

Thanks for your message regarding the Model Risk project. I think it's a very
important issue and really critical to Enron. The model risk represents a
very significant exposure to the company: a wrong model results in bad
decisions and eventually leads to accounting errors and incorrect financial
statements.

Here are my comments.

1. Reasons of model risk. The main source of model risk in Enron is omitted
in your list. I think it's due to the fact that the responsibility for the
final model approval and validation is dispersed in the organization and
there no single unit/person that is vested with the authority to audit,
approve and monitor valuation models. The popular perception is that this is
done by the Research Group, but this could not be further form the truth.
Given the way the organization evolved over the last few years, we became a
group of internal consultants, working on highly specialized, partial
problems (sometimes, we work on a project from A to Z, but it's an exception
to the rule).

It's imperative that this is communicated to the senior management in a
precise, non-ambiguous way. I think that this is the main source of potential
problems and the first shortcoming of the modeling process to be corrected.

2. I would expand point 3 in your draft (inappropriate application of models)
and add two lower level points: a) wrong inputs b) incorrect model used for a
given transaction. TVA is an example of point a: a transaction in case of
which the inputs have not been being updated for an extended period of time
in the past.

3. Under Control Strength you can mention that several audits of the Research
Group model by Arthur Andersen and Darrell Duffie have been initiated at our
insistence.