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2022 COMMENTS & CONTRIBUTIONS | Who Delivers the Post to the Postman?

2022 COMMENTS & CONTRIBUTIONS | Who Delivers the Post to the Postman?

by Starling Insights

Starling Insights Editorial Board

May 15, 2022

Compendium

Misconduct often occurs, as Kay notes, without any obvious ‘controlling mind’ that can be held culpable. And because regulators will not typically direct firms in how they are to manage their conduct risk governance — firms are expected to work out the details themselves — this can leave regulators casting about for information without knowing what they should be seeking, or where precisely it is to be had. Firms, meanwhile, struggle to evidence that their risk governance efforts should be seen as adequate, not knowing what metrics regulators will find compelling.

“ G is key. ”

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