Culture in financial services firms is – if not exactly a buzzword – more of a concern to regulators today than some of the themes that have historically preoccupied them.
Hardly surprising, given numerous failures of culture stretching back to the 1980s when governments across the world started deregulating markets: financial crises, bank collapses, huge losses, taxpayer bailouts, corporate and individual misdemeanours – many helped along the way by severe problems in the culture of the failing firms.
I’m not going to use this blog to re-hash war stories that have already had ample publicity and coverage over the decades.
Instead I want to focus on what culture in financial services firms means, partly informed by my own experiences past and current. How do firms formulate and package their culture? Can the language that a firm uses in its external and internal communications provide any leading indicators of its culture?
Can stakeholders such as regulators, depositors, investors, employees and suppliers identify and recognise the underlying culture of a firm, in the absence of adverse – but lagging – indicators such as critical losses, collapse or regulatory failure? What signs or behaviours might be revealing of a shallow or expedient culture?
There are lots of good articles out there on capitalisation including this one by my friend and professional colleague Julian Maynard-Smith.
Why make room for another in the packed internet content stall?
The answer is that, of all the style conundrums, whether or not to capitalise is one of the trickiest and most intractable, especially in the grey areas.
And one that is evolving rapidly. Internet anyone? Only a short while ago capital ‘I’ was the norm: no longer.
So I have no shame adding the Prism-Clarity view to the capitalisation fray. There are so many idiosyncrasies that it might be empowering to know that we can in some circumstances even if others don’t or we feel we shouldn’t.
I will follow the approach I have used for other style conundrums: Always Never Sometimes.
The Fundamental Review of the Trading Book (FRTB) is still a long way away – January 2022 at the latest estimate. But the time will pass quickly. Banks with trading activities need to be planning towards it now or soon.
This blog is derived from a piece of work I did recently for a potential client. It suggests an approach to defining a Target Operating Model (TOM) for implementing the FRTB.
In truth this will be mainly of interest to banks which have not yet started their FRTB planning. For example subsidiaries, smaller banks, and banks with marginal trading activities but exceeding the de minimis exemptions.
Most large banks are well under way with FRTB implementation, and have been for some time, participating in industry groups, Basel Quantitative Impact Studies (QIS) and routine monitoring, getting buy-in from their business leaders, corporate program leaders and strategic IT planners.
But smaller banks, in my experience, are not. Understandably, they prefer to wait and see. There are no real advantages to being first movers in this initiative, which has already evolved far – though not beyond recognition – since 2012.
With so many uncertainties along the path, including Brexit and the strategic regulatory and policy intentions of the US Administration, being in mid-pack is a smart play.
Still, it is worth having a long-term think ahead about how you might eventually implement these rules if you haven’t already.
*** Note: This blog does not constitute advice, but please contact Prism-Clarity for further information, including where to get the best advice. ***
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