As with any innovation and application of new technology, critical questions are emerging. For example, reliance on complex algorithms or machine learning tools raises issues around “explainability” and a clear audit trail. Lawyers will inevitably opine on a variety of issues, including data protection and privacy. Beyond strictly legal issues, firms will have to wrestle with questions about fundamental fairness and the consequences that techniques perceived as unduly intrusive and untrusting may have on employee morale and industry retention. As new technologies spread and their use grows in areas related to compliance and internal assessments, we will need to confront these issues. Conclusions To conclude, the culture of a financial firm, and of the industry as a whole, is a complex phenomenon that is not easy to measure or manage. Collectively, however, we must not ignore this issue. Looking ahead, members of the financial industry with different roles and perspectives can each take practical steps to move this dialogue forward. Financial firms should continue to develop and implement programs to build cultural capital, with directors, senior management, and staff each having distinct responsibilities and perspectives. Supervisors around the globe should remain committed to staying up-to-date on industry advances while continuing to develop and implement innovative supervisory approaches. We should continue to collaborate with the industry, the academic community, and other parts of the official sector. We should continue to monitor progress on industry benchmarking as more jurisdictions take up these efforts.
In December 2017, the chief executives of the five main retail banks in Ireland informed the Department of Finance of their intention to establish an Irish Banking Standards Board.12 In the U.S., the idea of industry benchmarking has been raised and discussed in the past, but no industry action has emerged to move this idea forward. At the New York Fed’s workshop on culture measurement and assessment, several participants recommended either joining the BSB’s benchmarking survey or creating a similar U.S. organization.13 Some noted that it would be helpful to include non-banks in the effort, and to collaborate with other corporations that have experience building strong cultures. Participants also discussed the importance of sharing 3/6  BIS central bankers' speeches  “lessons learned” and developing best practices as an industry. In my view, these types of industry-led initiatives can offer useful insights as firms compare and contrast their efforts and outcomes with peers. Official Sector A final perspective is that of the official sector. In my view, there is a clear role that follows the traditional focus on prudent risk management and the goal of building resilience. This reflects both the direct impact to firms mentioned above and the potential for industry-wide spillover if conduct and performance issues at one firm cause customers, counterparties, and investors to lose trust in the industry as a whole. This type of spillover suggests a role for the official sector to coordinate efforts and push the industry forward.