In the production of this annual report, we seek to remain neutral chroniclers of events that have transpired over the last year, curating and collating information from around the world regarding a regulatory and supervisory reform agenda that addresses culture and conduct related risks in the financial sector. We work to identify emerging consensus views and key points of departure, and we endeavor to establish a platform across which industry participants may address one another usefully. We also try to look ahead and to offer suggestions as to what we are likely to see in the coming year—not aiming to “predict” the future per se, so much as to feel along its edges in an attempt to trace the shape of it.
Among the Key Takeaways featured in our 2019 Compendium, we listed the expectation that we would see increased attention to culture as a key driver of behavior within firms. Against a backdrop of proliferating individual accountability regimes, we anticipated attention would shift from whether culture was a proper management and supervisory concern to how we may best operationalize culture and conduct risk governance and supervision. We argued that behavioral science would play a growing role in this context. We felt that a trend towards greater knowledge-sharing and coordination among regulators worldwide would expand. An emerging ecosystem of regulators, financial institutions, and technologists was expected to explore emerging ‘regtech’ tools more closely. We observed that the culture and conduct reform dialogue had come to embrace broader social interests that fall more typically under the ESG agenda—gender parity being one such. We noted that firms were struggling to evidence their success in mitigating culture and conduct risks and we argued that this may result in calls for agreed industry-standard metrics—both for internal governance purposes and to report up to regulators and other interested stakeholders. We got a lot of that right.
But nothing would have allowed us to anticipate the circumstances under which we write this year’s report. The pages that follow detail how the trends we listed in our 2019 Compendium have played out over the last 12-months—and there is much to report in that regard. As we write, however, the world is gripped by the COVID-19 global health crisis and all of its attendant economic consequences. This forces us to "zoom out” to encompass Big Picture trends before “zooming in” to consider the past year’s detail with adequate perspective.
So, permit us to zoom out a bit…
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