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Banking on a dispensation

News that Credit Suisse chairman António Horta-Osório was found to have breached Swiss COVID quarantine rules a second time — to go to the Wimbledon tennis 🎾 championships (story below) — gave me an idea.


As we know, given the history of the industry, financial services regulators focus extensively on conduct — not just what firms do, but how they do it. And when I say ‘firms’, of course, I mean the people within them. Particularly those in senior positions.


Rightly, regulators are also looking beyond compliance with their own rule books. In 2014, a UK fund manager was banned by the Financial Conduct Authority from working in Financial Services for repeated fare evasion on the railway. The rationale the regulator used for this was that this illustrated he was not “fit and proper” because he lacked “honesty and integrity”


I think the same argument could be made about compliance with COVID rules. The virus doesn’t distinguish between senior business leaders doing ‘essential’ business travel and everyone else. It’s a great example of a requirement that none of us likes, but we all know about and can all understand might be necessary.


So here’s a simple idea for conduct (and other) regulators. Deploy a technique that you probably use for your own rulebooks, in relation to COVID restrictions. Ask firms to provide details of all overseas travel undertaken by senior people during the pandemic, together with confirmation that it complied with all applicable COVID regulations and guidance. Where that isn’t the case, they can obviously provide you with an explanation.


You’ll probably get pushback. In part, because it’s not a question they’ll be expecting. Which is precisely why it might produce some interesting insights into what senior leaders actually think of complying with rules…




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