Banking Regulation Towards Advisory: The 'Culture Compliance' of Banks and Supervisory Authorities

Abstract

The financial regulation is moreover based on self-regulation and the coordination of external and internal supervision. This determines an evolution in the role played by the supervisory authorities, and in the manner in which they interact - with and almost advisory function - with the governance bodies of the banks, such as the board of directors, top management and external and internal auditors. The capacity to adequately perform such advisory functions entails the existence of consistent objectives, consistent knowledge and consistent cultural models. Our paper points at cultural gaps as a possible stumbling block in the efficient exchange of information and the sharing of problems and goals among regulators and the industry. We develop a cultural survey based on the application of a text-analysis model to a corpus of reference texts produced by two samples, drawn from among the supervisory bodies and the supervised entities. The empirical survey results reveal numerous fields of cultural differentiation, alongside several important areas in which the orientations of the two parties tend to overlap.

Keywords: Financial regulation, banking culture, cultural compliance, text analysis

JEL Classification: M14, N20