Contributions to the Supervisors on Supervision Stocktake
Should culture, and the conduct proclivities it may promote or discourage among employees, factor into supervisory engagements?
“The failure of Lehman Brothers had led to significant losses for the general public on complicated structured financial derivatives. People lost their shirts and didn't know what they were buying. Even more seriously, the bank staff who marketed these products didn't know what they were selling. This is a culture problem.”
"You're driving down a highway. Now people say there are no more rules, no more speed limits, no more lane markings. Hooray. Really? Is it safer driving down that highway now? You're going to have to rely on your own driving skills to avoid crazy drivers and do the right thing. You have to have your own true north inside you to tell you where your speed limit is, not just follow what the car next to you is doing.”
What role does culture play in governance failures that ultimately require supervisory attention?
“Culture has to be top-down. It's the basic principles or values that influence a person's behavior. However, there could be subcultures within a large bank. It's not that the board said, ‘Let's go open false accounts for $25 each.’ I cannot imagine senior management or the board would quietly approve that. That was a case where the overall culture from the top was good — Wells Fargo is otherwise a very well-managed, conservative bank — but a subculture existed.”
What are the consequences for failing to consider the influence of culture in assessments of governance effectiveness?
“Credit Suisse's prudential benchmarks were hit time and again by things like mis-investment and customer fraud, which led to a collapse in customer confidence and a very unfortunate outcome.”
What have we learned from past approaches to culture risk governance and supervision?
“It wasn't long ago that a trading desk team would be allowed to share around 30% of the trading profits for that year as a bonus. I think that's wrong. These are the brightest people in the world, but they are risking the bank's capital. If they win, they get 30%; if they lose, the worst that can happen is they get fired and go somewhere else. You get situations like the ‘London Whale’ at JP Morgan. That colossal loss was manageable for JP Morgan's balance sheet, but imagine if it happened to a different bank.”