Since the 2008 global financial crisis, the financial services industry has wrestled with culture within banks and firms. Some parties assert culture substantially contributed to the crisis and was perhaps the primary factor. Politicians summoned the CEOs of big banks as well as regulatory leaders to explain what happened. We subsequently learned business practices had marginalized and/or disregarded compliance risk management in pursuit of profit without boundaries, customers without protection, and business deals without logic.

Many believe culture is all about conduct, but this assumes culture is measured by actions taken, decisions made, and business opportunities pursued. Of course, conduct is the output, but the culture sitting behind the conduct is based upon tolerance and, simultaneously, intolerance.