The OCC is the primary federal supervisor of many large US banks. After the financial crisis, Comptroller Thomas Curry heightened supervisory focus on the culture of firms. “Addressing the risk culture within the banking system was an early priority of mine as Comptroller, and I continue to make it a theme of conversation with bankers, examiners, and other regulators.”1
He also explained why he was focused on culture. “At the end of the day, however, regulations only go so far, and systems of internal control are no stronger than the culture that surrounds them. We can’t write rules to cover every conceivable situation that might come up, and risk officers are only as effective as the support they receive from top management, which is another way of saying that they can only be as effective as their bank’s culture will permit.”2
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