JPMorgan Chase Settles Mortgage Claims for $13 Billion

, The National Law Journal

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  • Mark Rome

    ?No firm, no matter how profitable, is above the law, and the passage of time is no shield from accountability.?

    Like so many banks, JPMorgan has ended up with multiple sources of policy, training, surveys, assessments and issue reporting hotlines.

    To ensure mega-banks implement and maintain a high performance culture of compliance after settling allegations of fraud and mismanagement, regulators should demand improved transparency into operations and request access to internal systems:
    1) Direct feed monitoring systems (e-mail, trades, etc.)
    2) Effective policy management (utilizing an online policy library)
    3) Ongoing culture assessment surveys
    4) Performance Scorecards (hard & soft metrics)
    5) Event management and reporting
    6) Annual certifications to the Code of Conduct

    Within every organization, decision making drives performance. Every employee comes to work every day and makes decisions that impact performance. These decisions, at every level of the organization, define the corporate culture and drive performance.

    An essential role of bank leadership should be to acquire data on how well individual roles align with corporate goals and strategy, and design incentives that encourage and reward performance, while enforcing compliance will applicable laws, rules and regulations?

    With the right tools and the right data, leadership can better understand its workforce to align the culture (decision making) with corporate goals and drive performance, and regulators should be keeping close watch.

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