Reactive interior at CBA
For a bank undisciplined at considering risk, one wonders how deeply stakeholders have delved into the report of APRA's prudential inquiry headed by John Laker, released at the end of April.The bank's Executive Risk Committee "was not an effective vehicle for addressing group-wide risks and issues," the Laker report found."Its mandate did not include oversight of the risk profile of the group, while its dynamics did not encourage a sense of collective accountability for group risk outcomes or constructive challenge of committee members."Treasurer Scott Morrison at the time called for resignations all round, from the board and the brass. Few have been forthcoming."The panel observed imbalance between the 'voice of finance' on the one hand, and the 'voice of risk' and the 'customer voice' on the other," Laker's report stated."CBA's investment prioritisation process in design and practice has generally only addressed risk, compliance and resilience issues on a reactive basis once these become 'high rated' issues, [while making] trade-off decisions in which financial objectives were implicitly prioritised over the 'customer voice'."It is only on the cusp of the crisis enveloping the bank that CBA has found a budget for "strategic risk IT infrastructure", as Banking Day reported at the time.The panel wrote that "CBA's 'default response' to being challenged [by regulators or an ombudsman] was a legalistic and defensive posture.The panel said it "heard of occasions where CBA would insist on hearing why it was legally required to take action before it would do so. This adversarial approach appeared to put strict legal interpretation above risk or customer outcomes. "Observations were also made on the difficulty of obtaining cooperation on matters where the group legal department had already provided a response. A more cooperative and less legalistic response would only be provided if the matter was escalated to CBA's senior management. "The Panel noted a theme from interviews suggesting slowness or disinterest in responding to regulatory concerns. This included difficulties in prioritising concerns that were raised on a preemptive basis, and frequent delays in complying with regulatory requests. "The Panel heard of positive messaging put on risk issues, including an emphasis on the relative advantages CBA claimed it had compared to peers, and the downplaying of risks where no loss had yet been experienced."Obstruction is the bank's MO."Interviewees noted that some regulatory concerns raised had been met with a response that the concerns were already known and considered not as important as other priorities, which would receive more urgent attention. "This approach can be juxtaposed with instances where CBA staff sought requirements from the regulator in order to prioritise funding for remediation programs. "The Panel also heard evidence that CBA was less proactive and slower to comply with regulators compared to some peers. This was demonstrated by CBA's inclination to wait for the regulator to make initial contact following the emergence of an issue, or to rely on regulators sharing information rather than approaching other regulators with an interest in an issue. "Interviewees interpreted this as a reluctance to proactively