This point raises the oft-cited concern about “supervisory trickle down,” whereby supervisory expectations – or even regulatory requirements – formulated for larger banks are de facto applied in part to community banks. The concern has been particularly acute in the context of capital stress testing, though it is by no means limited to that area.
These values must filter down to all aspects of the organisations. And we must align our system to reward those that uphold these values. We have therefore integrated the organisational values with our formal recognition and reward system in the Bank. Alignment to these values now determines the rewards that one will be awarded at year end.