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Due Process vs Do Process

Assessment of management capabilities and of risk governance efficacy remains a largely subjective supervisory exercise, shrouded in secrecy by design. Without reliable objective metrics, even the most well-intended supervisors are open to charges of indefensible tick-box analysis (“do process”) while firms may conclude that litigation is necessary to assure bank examination follows some due process.

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Cultures of Trustworthiness: The Role of the Regulator

by Henry Farrell


Jun 11, 2024

Regulators focus on formal, quantifiable aspects rather than informal, qualitative ones. Trust and trustworthiness are essential for effective regulation, beyond mere rules. Regulators should enhance cultures of trustworthiness within organizations and consider the broader public trust. This requires balancing formal rules with fostering a culture that supports and exceeds compliance.

The 2024 Compendium is available June 11th!

Now in its 7th year, Starling's Compendium features over 40 contributors from across the industry as well as detailed analysis of the latest trends in culture & conduct risk supervision.