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6 - Regulating Agency Relationships and Risk Culture in Financial Institutions

from Part II - A View of Risk Culture Concepts in Firms and Society

Published online by Cambridge University Press:  22 May 2020

Michelle Tuveson
Judge Business School, Cambridge
Daniel Ralph
Judge Business School, Cambridge
Kern Alexander
Universität Zürich
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The chapter analyses the role of financial regulation in facilitating the development of organizational norms to enhance risk culture in financial institutions. The paper suggests that shortcomings in risk culture – particularly as understood through the lens of human agency theory – in large financial institutions are the result of collective agency problems. The paper argues that regulation has a role to play in addressing collective agency problems but that regulators should be selective in what tools they use to enhance risk culture in institutions with consideration given to the regulation of remuneration and trusted financial products. It further suggests that to address collective agency problems in large financial institutions policymakers should consider the utility of a senior managers’ liability regime to incentivize senior officers and board directors to be more proactive and aware of misconduct and other behavior that results in agency costs for the firm and society. The paper concludes that a effective regulation involves a balance between official sector regulation and self-regulation that can channel the collective actions of individuals to improve governance and operations in a way that benefits overall firm performance and which mitigates socially costly behavior.

Beyond Bad Apples
Risk Culture in Business
, pp. 165 - 189
Publisher: Cambridge University Press
Print publication year: 2020

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Ashby, S., Palermo, T. and Power, M., (2014). Risk culture: definitions, change practices and challenge for chief risk officers. In Patricia, J., ed., Risk Culture and Effective Risk Governance. London: Riskbooks.Google Scholar
Bailey, A. (2016). Culture in financial services – a regulator’s perspective. Speech at the City Week 2016 Conference, 9 May 2016. Scholar
Bandura, A. (1986). Social Foundations of Thought and Action. Englewood Cliffs, NJ: Prentice–Hall.Google Scholar
Bandura, A. (1997). Self-Efficacy: The Exercise of Control. New York: W. H. Freeman.Google Scholar
Bandura, A. (1999). Social cognitive theory of personality. In Pervin, L. A. and John, O. P., eds., Handbook of Personality. New York: The Guildford Press.Google Scholar
Bandura, A. (2000). Exercise of human agency through collective efficacy. Current Directions in Psychological Science, 9(3), 75–8.CrossRefGoogle Scholar
Bandura, A. (2006). Toward a psychology of human agency. Perspectives on Psychological Science, 1(2), 164–80.CrossRefGoogle Scholar
Bandura, A. (2009). Agency. In Carr, D. S., ed., Encyclopedia of the Life Course and Human Development. Detroit: Macmillan Reference USA.Google Scholar
Bank of England and Financial Services Authority (2011). The Bank of England, Prudential Regulation Authority – Our Approach to Banking Supervision.Google Scholar
Banks, E. (2012). Risk Culture: A Practical Guide to Building and Strengthening the Fabric of Risk Management. Basingstoke: Palgrave MacMillan.CrossRefGoogle Scholar
Baxter, J. and Megone, C. (2016). Exploring the Role of Professional Bodies and Professional Qualifications in the UK Banking Sector. London: Banking Standards Board. Scholar
BCBS (Basel Committee on Banking Supervision) (2009). Enhancements to the Basel II Framework. Scholar
BCBS (Basel Committee on Banking Supervision) (2014). Consultative Document: Corporate Governance Principles for Banks. Scholar
BSB (Banking Standards Board) (2016). Annual Review 2015/2016. Scholar
CB:PBS (Chartered Banker Professional Standards Board) (2016a). CB:PSB Progress Report. Scholar
CB:PBS (Chartered Banker Professional Standards Board) (2016b). Foundation Standard Requirements for Professional Bankers. Scholar
CB:PBS (Chartered Banker Professional Standards Board) (2018). The Chartered Banker Code of Professional Conduct. Scholar
Dow, J. (2000). What is systemic risk? Moral hazard, initial shocks, and propagation. Monetary and Economic Studies, 18(2), 124.Google Scholar
Dunkley, E. (2015). UK draws line under ‘banker bashing’ after scrapping assessment. Financial Times, 2015 December 30. Scholar
Emirbayer, M. and Mische, A. (1998). What is agency? The American Journal of Sociology, 103(4), 9621023.CrossRefGoogle Scholar
Ernst & Young (2014). Shifting Focus: Risk Culture at the Forefront of Banking. Scholar
ESRB (European Systemic Risk Board) (2015). Report on Misconduct Risk in the Banking Sector. Scholar
FCA (Financial Conduct Authority) (2015). CP15/22 Strengthening Accountability in Banking: Final Rules (including Feedback on CP14/31 and CP15/5) and Consultation on Extending the Certification Regime to Wholesale Market Activities. Scholar
FMSB (FICC Markets Standards Board) (2016a). FICC Markets Standards Board proposes greater transparency in new issue process for debt. FMSB, 2016 November 18. Scholar
FMSB (FICC Markets Standards Board) (2016b). Statement of Good Practice for FICC Market Participants: Conduct Training. Scholar
FMSB (FICC Markets Standards Board) (2016c). Surveillance Core Principles for FICC Market Participants: Statement of Good Practice for Surveillance in Foreign Exchange Markets. Scholar
FMSB (FICC Markets Standards Board) (2017). New Issue Process Standard for the Fixed Income Markets. Scholar
Foreign Exchange Professionals Association (2015). Focus On: Foreign Exchange Benchmarks. Scholar
FSB (Financial Stability Board) (2014). Guidance on Supervisory Interaction with Financial Institutions on Risk Culture: A Framework for Assessing Risk Culture. Scholar
G30 (Group of Thirty) (2013). A New Paradigm: Financial Institution Boards and Supervisors. Scholar
G30 (Group of Thirty) (2015). Banking Conduct and Culture: A Call for Sustained and Comprehensive Reform. Scholar
Hart, O. (1995). Firms, Contracts, and Financial Structure. Oxford: Oxford University Press.CrossRefGoogle Scholar
House of Commons (2011). Uncorrected transcript of oral evidence, to be published as HC 1447-xii. Oral evidence taken before the Joint Committee on the Draft Financial Services Bill, 8 November 2011. Scholar
HM Treasury (2012). The Wheatley Review of LIBOR: Final Report. Scholar
HM Treasury (2015). Senior Managers and Certification Regime: Extension to All FSMA Authorised Persons. Scholar
HM Treasury, Bank of England and FCA (Financial Conduct Authority) (2015). Fair and Effective Markets Review: Final Report. Scholar
Hölmstrom, B. (1979). Moral hazard and observability. The Bell Journal of Economics, 10(1), 7491.CrossRefGoogle Scholar
IIF (Institute of International Finance) (2009). Reform in the Financial Services Industry: Strengthening Practices for a More Stable System. Washington, DC: IIF.Google Scholar
Jensen, M. C. (1998). Foundations of Organizational Strategy. Cambridge, MA: Harvard University Press.Google Scholar
Jensen, M. C. and Meckling, W. H. (1976). Theory of the firm: managerial behavior, agency costs, and ownership structure. Journal of Financial Economics, 3(4), 305–60.CrossRefGoogle Scholar
Jensen, M. C. and Meckling, W. H. (1994). The nature of man. Journal of Applied Corporate Finance, 7(2), 419.CrossRefGoogle Scholar
Khurana, R. (2002). The curse of the superstar CEO. Harvard Business Review, 80(9), 60–6.Google ScholarPubMed
Lambert, R. (2014). Banking Standards Review. Scholar
Malmendier, U. and Geoffrey, T. (2009). Superstar CEOs. Quarterly Journal of Economics, 124(4), 1593–638.CrossRefGoogle Scholar
McDermott, T. (2015). Culture in banking. Speech to the British Bankers Association. Scholar
Nouy, D. (2015). Towards a new age of responsibility in banking and finance: getting the culture and the ethics right. Speech at Goethe Universität, Frankfurt, 23 November 2015. Scholar
Ostrom, E. (2008). Tragedy of the commons. In The New Palgrave Dictionary of Economics. Basingstoke: Palgrave Macmillan.Google Scholar
PCBS (Parliamentary Commission on Banking Standards) (2013a). Changing Banking for Good, vol. 1. Scholar
PCBS (Parliamentary Commission on Banking Standards) (2013b). Changing Banking for Good, vol. 2. Scholar
Peltzman, S. (1975). The effects of automobile safety regulation. Journal of Political Economy, 83(4), 677726.CrossRefGoogle Scholar
PRA (Prudential Regulation Authority) (2014). The Use of PRA Powers to Address Serious Failings in the Culture of Firms. Scholar
Ralph, D. and Tuveson, M. (2015). Is regulation of risk culture the missing piece? Civil actions reconsidered. Banking and Financial Services Policy Report, 25(1), 1218.Google Scholar
Ross, S. A. (1974). On the economic theory of agency: the principle of similarity. In Balch, M., McFadden, D. and Wu, S., eds., Essays on Economic Behavior under Uncertainty. Amsterdam: North-Holland.Google Scholar
Sants, W. H. (2010). Do regulators have a role to play in judging culture and ethics? Speech at the Chartered Institute of Securities and Investments Conference, 17 June 2010. Scholar
Shleifer, A. and Vishny, R. (1997). A survey of corporate governance. Journal of Finance, 52(2), 737–83.CrossRefGoogle Scholar
Tversky, A. and Daniel, K. (1974). Judgment under uncertainty: heuristics and biases. Science, New Series, 185(4157), 1124–31.Google ScholarPubMed
Walker, P. (2016). FCA drops banking culture review. FTAdviser, 2016 January 4. Scholar

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