Category Archives: Culture


“U.S. Prosecutors to Weigh Criminal Case for McCabe,” The Wall Street Journal, April 20, 2018 A1. The DOJ Inspector General referred the case/matter of former FBI Deputy Director for criminal prosecution over his responses to investigators looking into leaks.

What does it say about the culture of an organization when two of its top officers, both of whom are lawyers, may have lied to federal investigators?  And what if that organization’s mission is the investigation of crimes?

How much do we rely on institutions and professionals to provide governance and to stand as examples of compliance?  Is that reliance justified?


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Filed under Compliance, Compliance (General), Controls, Culture, Duty, Employees, Governance, Government, Lawyers, Legal, Requirements


Wells Nears $1 Billion Settlement,” The Wall Street Journal, April 20, 2018 B1.

Wells Fargo is about to be (has been) fined close to $1 billion for irregularities regarding auto loans, auto insurance,  and mortgage loans.  This is the civil side.  This is in addition to the $185 million for the account cramming scandal in 2016, where the bank opened new accounts and credit cards that consumers did not request.  The Chief Risk Officer is also retiring.

Once again, the shareholders pay mightily for the sins of (mis-)management.

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Filed under Compliance (General), Culture, Governance, Risk, Risk assessment, Supervision


When you need to hide relevant information from your clients, you are often doing something that’s not ethical.

“BofA to Pay Fine Over ‘Marking’ of Trades,” The Wall Street Journal, March 24, 2018 B10.  Bank hid the fact that it was routing its clients’ trades through high-speed trading firms.  Millions of times.  Apparently, the scheme was well known by bank employees, and was to hide the bank’s practices from major clients who would have objected.  And they did it anyway.  Cost: $42 million fine, and a loss of a lot of face.

You’d think a bank would have a policy or maybe even a culture against lying, cheating, or stealing.  Who’s getting fired?


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Filed under Compliance, Compliance, Compliance (General), Controls, Corporation, Culture, Duty, Employees, Governance, Management, Oversight, Policy, To report

Don’t forget who your audience is

“Angry Users Are Threat to Facebook,” The Wall Street Journal, March 23, 2018 B1.  User reaction to the use of user data may imperil FB; users lose trust.

For a company recently valued at $500 billion, the loss of a customer base and momentum may be terminal.  Or at least painful.  Just because they didn’t take care of its users’ information.

Again, is this an information governance blog or a crisis management and response blog?  The issues seem to overlap a good deal of late.  Is this just a risk of the business, or does it say something about the company’s culture or governance?  What exactly is FB selling, and to whom?  What was their reputation?

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Filed under Board, Controls, Corporation, Culture, Culture, Duty, Governance, Internal controls, Oversight, Oversight, Protect assets, Protect information assets, Risk Assessment, Third parties, Vendors

Secondary compliance

“More Firings at BofA Amid Misconduct Claim,” The Wall Street Journal, March 1, 2018 B1.  Two employees fired for interfering in investigation into allegations of sexual misconduct by another employee.  They may have gotten together to get their stories straight.

What does this say about culture at BofA?  Not just that there’s another instance of alleged sexual misconduct, but also that people would think they could influence the process?

Again, how do you protect against this type of behavior?  Is it enough to just publicly fire the violators?  Do you teach on the perils of interfering with an internal investigation?  This is, in all likelihood, solely a violation of policy (assuming you can find a policy that governs).  Maybe bad ethics?


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Filed under Board, Compliance, Compliance, Controls, Corporation, Culture, Culture, Duty, Employees, Governance, Internal controls, Oversight, Supervision, To report

Raining, pouring

Wells Fargo has had a rough year or two, following the account-cramming scandal.  Then there was the auto insurance issue.  And the mortgage issue.  Now the rot has leaked into the wealth business.

“Wells Wealth Business Under Fire,” The Wall Street Journal, March 2, 2018 B1.  A whistle blower reports on problems in the wealth-management business.  Investigation follows.

Shearman & Sterling, who wrote an earlier report on the account-cramming matter (and who may be taking up residence), is investigating.

From a governance standpoint, if you find one roach, expect to find others.  Perhaps an infestation.  Is it cultural?  Or not having sufficient pest control?  Was the Board napping?

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Filed under Board, Compliance, Controls, Culture, Culture, Directors, Duty, Governance, Internal controls, Oversight, Oversight

Two to tango

Two interesting stories on page B1 relating to governance:

“Ford Official Fired for Misconduct,” The Wall Street Journal, February 22, 2018 B1. Top executive fired for unspecified bad conduct.

“Disney Producer’s Behavior Criticized,” The Wall Street Journal, February 22, 2018 B1. Successful producer may act and speak inappropriately, but is still running the high-profile “Frozen” production.

How important is context?  One would think that the entertainment industry would be more sensitive than other industries in avoiding any hint of inappropriate (the PC term) behavior, and Disney in particular.

How does your company manage its culture?  Does it enforce the rules against top managers, or big money producers?  What does the Board say, both now and when something goes wrong (or is discovered) later?  Are violations and punishments publicized internally?

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Filed under Board, Communications, Compliance, Compliance, Controls, Corporation, Culture, Culture, Directors, Duty, Duty of Care, Employees, Governance, Inform market, Inform shareholders, Internal controls, Oversight, Oversight, To report