The Institute of Internal Auditors held its global conference in Boston last week, bringing together more than 3,000 audit, risk and compliance executives to talk about all things related to the field. Good advice abounded, but the best insight I heard came (as it often does) in the form of a wisecrack more wise than the speaker may have understood.
The speaker was Rebecca Rhoads, CIO of Raytheon Corp. She was participating in a panel discussion about executive leadership and decision-making in the future, and off-handedly quipped, “I thank God I lived my teen-aged years in a time before they were discoverable.”
A funny line, for sure. But re-interpret those words into the converse—that we all now live in a time where everything is discoverable—and then think about how you and your corporate colleagues will do your jobs in that world. Brace yourselves.
After all, life in the discoverable world was the undoing of Russell Wasendorf, the apparent fraudster and former CEO of Peregrine Financial Group who attempted suicide last week. All evidence, including Wasendorf's own suicide note, suggests that he lied about Peregrine's financial resources for years by falsifying paper-based bank statements. Only when the National Futures Association started using electronic audit methods did the fraud become clear, and Wasendorf hitched a rubber hose to the tailpipe of his car.
The Peregrine fraud is an example of how life in the discoverable world can work for good. Now consider the example of JP Morgan and its fabled London Whale scandal, the backfired trades on European debt that so far have cost the firm $2 billion—or maybe $4 billion, or maybe the $5.8 billion JP Morgan announced last Friday when it had to restate earnings, or maybe the $9 billion some analysts estimate. Nobody really knows the total loss yet, and that's the criticism fired at CEO Jamie Dimon right now: How could the bank not know what risks it had been carrying? After all, the critics say, we live in a discoverable world. So somewhere in all those millions of trading records that JP Morgan has on file, the bank should have understood the size of the bets its traders were making—and yet, it didn't.
Even regulators themselves are about to be slammed by life in the discoverable world, courtesy of the LIBOR trading scandal. First scalped were the chairman and chief executive of Barclays, but now evidence has surfaced (read: “has been discovered”) that Barclays actually informed the British Financial Services Authority of possible fraud in the LIBOR rate as far back as 2007. Our own Treasury Secretary here, Timothy Geithner, expressed worries about LIBOR as far back as 2008 while he was still head of the New York Federal Reserve Bank. Parliament plans to haul FSA leaders into a hearing this week, and I have every confidence that Congress will do the same to Geithner sometime soon.
These examples are merely the first jolts of profound growing pains Corporate America and compliance executives are about to undergo. Technology is moving into an era where every business operation and transaction can be boiled down to a piece of data, and every piece of data stored for quick and ready reference. My suspicion is that the blurring of roles we've already seen among compliance, risk, audit, and IT executives is going to accelerate. I'll even coin a new phrase for what that role might ultimately look like: the chief transparency officer.
Whether your corporation ultimately creates one chief transparency officer or assigns those duties to a team, that person or persons is going to have some tough questions to answer. Who is responsible for what in that world? How do you catalog all the data you have? What's the correct system to search all that data for the right information you need at the right time? Who reports what to whom?
And, above all, how can a company take risks when every risk can be documented—and every failure, consequently, be assigned to a specific decision made by a specific person? I wouldn't relish working in a world where every wrong decision or lapse in oversight turns into retroactive proof of stupidity, and neither would you. But that's what life in the discoverable world looks like so far.