A Starling Insights Deeper Dive Report

Supervisors on Supervision

Public Exposure Draft

About This Report

Despite awareness that culture is a matter of supervisory, policy, and political concern, there has been no concerted effort to define the terms, consistently and across jurisdictions, that would permit for an intelligent discourse regarding culture as a practical interest. And without an established set of metrics by which to gauge the efficacy of culture risk governance, relevant practical interests go unmeasured and unmet.

Throughout our Compendium series and other publications, Starling Insights has chronicled the periodic and idiosyncratic efforts made by various organizations to grapple with culture as an economic interest and a policy priority. As that work details, absent clear starting points, welldefined objectives, and measurable outcomes, a coherent framework by which to assess and assure effective culture risk governance and supervision remains aspirational.

A collaborative global effort is necessary if culture is to be made tractable and if best practices for governance and supervision thereof are to be achieved. The “Supervisors on Supervision” report hopes to convene that effort.

Leadership Team

Study Chair:
Randal Quarles
Randal Quarles

Past-Vice Chair for Supervision

US Federal Reserve Board

Chapter Chairs:
Wayne Byres
Wayne Byres

Past-Chair

Australian Prudential Regulation Authority

Elizabeth McCaul
Elizabeth McCaul

Past-Member

European Central Bank Supervisory Board

Fernando Restoy
Fernando Restoy

Chair

Financial Stability Institute

Carolyn Rogers
Carolyn Rogers

Senior Deputy Governor

Bank of Canada

Secretariat:
Stephen Scott
Stephen Scott

Executive Editor &

Deeper Dive Series Lead

Erich Hoefer
Erich Hoefer

Deputy Editor

Starling Insights

Debra Cope
Debra Cope

Director of Media and Public Relations

Cameron Lawrence
Cameron Lawrence

Director of Research

Chapter Advisors:
David Bailey
David Bailey

Co-Chair of the Supervisory Cooperation Group

Basel Committee on Banking Supervision

Sarah Dahlgren
Sarah Dahlgren

past-Head of Supervision

Federal Reserve Bank of New York

Ben Gully
Ben Gully

Co-Chair of the Supervisory Cooperation Group

Basel Committee on Banking Supervision

Michael Hsu
Michael Hsu

past-Acting Comptroller of the Currency (US)

Eva Hüpkes
Eva Hüpkes

Secretary General

International Association of Deposit Insurers

Mirea Raaijmakers
Mirea Raaijmakers

past-Senior Supervisory Officer

De Nederlandsche Bank

Charles Randell
Charles Randell

past-Chair

UK Financial Conduct Authority

Bryan Stirewalt
Bryan Stirewalt

past-CEO

Dubai Financial Services Authority

Report Preamble

Opening Letter from the Chair

Randal K. Quarles

Past Vice Chair for Supervision for the US Federal Reserve Board and Chair of the report

Opening Letter from the Chair

Executive Summary

Stephen Scott

Executive Editor, Starling Insights and Deeper Dive Series Lead

Executive Summary

Stocktake Participants

Explore the 60+ contributors who share their views herein.

Chapter One — Culture as a Supervisory Concern

Chapter One At-A-Glance

Signals | Shared observations

Stakes | Observed consequences of the status quo

Summons | Opportunities and challenges to take up

Chapter One At-A-Glance

Preamble to Chapter One

Sir John Kay

Fellow of the British Academy and of the Royal Society of Edinburgh

Preamble to Chapter One

Executive Summary

Why this chapter exists.

What you'll see along the way.

Where this leaves us.

Executive Summary

Closing Comments

Carolyn Rodgers

Chapter Chair and Senior Deputy Governor, Bank of Canada

Closing Comments

Chapter One Stocktake

Chapter 1.1 — Definitional Ambiguity & Supervisory Hesitancy

Chapter 1.2 — The Case for Culture as a Supervisory Concern

Chapter 1.3 — Global Convergence & Divergence

Chapter 1.4 — Legitimacy & Trust

Chapter One Stocktake

Perspectives: Where Culture Meets Prudential Supervision

Charles Randell

past-Chair, UK Financial Conduct Authority

 

Perspectives: Where Culture Meets Prudential Supervision

Chapter Two — Consequences & Challenges

Chapter Two At-A-Glance

Signals | Shared observations

Stakes | Observed consequences of the status quo

Summons | Opportunities and challenges to take up

Chapter Two At-A-Glance

Preamble to Chapter Two

Sir Paul Tucker

past-Deputy Governor, Bank of England

Preamble to Chapter Two

Executive Summary

Why this chapter exists.

What you'll see along the way.

Where this leaves us.

Executive Summary

Closing Comments

Fernando Restoy

Chapter Chair and Chair, Financial Stability Institute

Closing Comments

Chapter Two Stocktake

Chapter 2.1 — The Cost of Delay

Chapter 2.2 — The Anatomy of Structured Discretion

Chapter 2.3 — Proportionate Early Action

Chapter 2.4 — Institutional Memory and Accountability

Chapter Two Stocktake

Perspectives: Failures of Culture, Risk, and Governance — The Credit Suisse Crisis

Eva Hüpkes

Secretary General, International Association of Deposit Insurers

Perspectives: Failures of Culture, Risk, and Governance — The Credit Suisse Crisis

Chapter Three — Past Efforts & Outcomes

Chapter Three At-A-Glance

Signals | Shared observations

Stakes | Observed consequences of the status quo

Summons | Opportunities and challenges to take up

Chapter Three At-A-Glance

Preamble to Chapter Three

Amy Edmondson

Novartis Professor of Leadership and Management

Harvard Business School

 

Preamble to Chapter Three

Executive Summary

Why this chapter exists.

What you'll see along the way.

Where this leaves us.

Executive Summary

Closing Comments

Wayne Byres

Chapter Chair and Past-Chair, Australian Prudential Regulation Authority

Closing Comments

Chapter Three Stocktake

Chapter 3.1 — Integration into Supervision

Chapter 3.2 — Innovation in Management

Chapter 3.3 — Supervisory Learnings to Date

Chapter 3.4 — Re-setting Institutional Memory

Chapter Three Stocktake

Perspectives: Supervisory Standards and the Slow Rise of Culture

Cameron Lawrence, Director of Research, Starling Insights

Sarah Dahlgren, past-Head of Supervision, Federal Reserve Bank of New York

Perspectives: Supervisory Standards and the Slow Rise of Culture

Chapter Four — Future Directions & Obstacles

Chapter Four At-A-Glance

Signals | Shared observations

Stakes | Observed consequences of the status quo

Summons | Opportunities and challenges to take up

Chapter Four At-A-Glance

Preamble to Chapter Four

Colin Mayer

past Dean, Saïd Business School, Oxford University


 

Preamble to Chapter Four

Executive Summary

Why this chapter exists.

What you'll see along the way.

Where this leaves us.

Executive Summary

Closing Comments

Elizabeth McCaul

Chapter Chair & Past-Member, European Central Bank Supervisory Board

Closing Comments

Chapter Four Stocktake

Chapter 4.1 — Avoiding Regulatory Drift & Distrust

Chapter 4.2 — The Pressure to Innovate

Chapter 4.3 — Making Room for New Metrics & New Tools

Chapter 4.4. — New Approaches & New Partnerships

Chapter Four Stocktake

Call for Comments

The “Supervisors on Supervision” report is now available as a Public Exposure Draft.

It is intended to solicit broad feedback from industry stakeholders which will inform a Final Report to be released in the second quarter of 2026.

As comments are received will be shared on Starling Insights.

Call for Comments