Contributions to the Supervisors on Supervision Stocktake
If culture is important to supervision, then what factors make it challenging to assess?
“A board can’t be expected to run the day-to-day governance, or culture and conduct of these large organizations, whatever industry you may be in.”
How does a lack of effective tools and frameworks for culture risk supervision impact perceptions of supervisory legitimacy?
“[M]ore surveillance and monitoring isn’t going to solve the problem of bad actors. There are some few people in any firm who will be smart enough to take their illicit activities offline.”
What role does culture play in governance failures that ultimately require supervisory attention?
“[T]he truth of the matter is that the senior management are often unaware of what’s going on in the core of their organizations. Despite best efforts, they’re often operating in the dark. Senior management is only as good as the data it works with, the information it receives through their reporting systems, and the layers of reporting that aggregates up to them.
The problematic issues are in the middle to the bottom of the iceberg. We can talk about the executive officers, and we can talk about the board, but they’re only as good as all the people down below them, and how ready they are to escalate critical information. We have to make sure our people are comfortable reporting the truth, reporting the bad news.”