“You are an investment adviser and manager for Outrageous Wealth Managers (OWM) which you joined recently, having worked for a number of years for Azure, a wealth management subsidiary of a major UK bank.”
So begins a question in the online ethics test that the UK’s Chartered Institute for Securities and Investment (CISI) requires all candidates for its qualification to take.
The test soon moves into the territory of fantasy role-playing games. On a train, you find yourself facing Bruce, a former colleague who admits that times are tough at Azure, and shuffles anxiously through his papers. When he leaves, you realise that he has left on top of a full rubbish bin a sheaf of possibly confidential papers, bearing the Azure logo. What should you do?
Candidates are given a multiple-choice set of options, leading to further ethical dilemmas. By the end it is not at all clear what the “right” answer is. The exercise captures the difficulty of behaving well in a financial environment. And you must pass if you want the qualification.
This is one of the more original ways of dealing with a long-running and difficult problem: how do you teach business students about ethics? And beyond the broad issue of ethics, how do you train them to deal with the specifics of regulations?
Many in financial services spend their lives trying to keep regulators happy. But as regulation adapts to a more complicated financial world, a new culture of outsourcing responsibility has emerged. Regulators set the rules, and often allow new companies and business models to take a pivotal role.
And yet the biggest business schools find it hard to prepare their students to joust with regulators. One problem is practical: these days, the top schools are global, but regulation is country-specific. There is little point in briefing students on US rules, if they are going to return to work in China. This problem tends to be farmed out to professional bodies, who often rely on candidates learning rules on the job.
Business schools restrict themselves to broader ethical issues. But that raises more dilemmas.
Some schools offer a standalone course in ethics – with the risk of implying that all other classes are unethical. Others attempt to “suffuse” all their curriculum with ethics – prompting students to complain that ethics are ultimately ignored.
Either way, dealing with specific rules is left unaddressed. And this is important because the default response to recent regulation has been to outsource responsibility, creating new vulnerability in the financial system.
Take for example the pre-crisis power of credit rating agencies. The “Basel II” bank regulations gave investors a big incentive to buy anything stamped triple A by agencies. That way lay disaster.
Ratings were only ever advertised as opinions, based on publicly available information: the agencies fell short when investment banks started trying to persuade them that products based on subprime mortgages should be rated triple A.
After the crisis, it is the Dodd-Frank legislation in the US that has had unforeseen consequences.
Companies must be more transparent with investors, who must take part in votes on executive pay.
The response, it appears, has been to leave investors relying on a few proxy companies for advice on how to vote as the easiest way to show regulators they have taken their duties seriously.
Not only regulations but the structure of capital markets foster a culture of “passing the buck”.
Bankers once knew they would suffer if a loan they made defaulted. Now, they can sell that risk on.
As the public has lost trust in the financial services sector, it is critical to inculcate a culture of greater responsibility. Who is going to do this?
The CISI’s online world of moral dilemmas is as imaginative an attempt at this as any. But surely such training needs to start earlier – in university or business school – and continue once candidates are on the job. Then, perhaps, when they do find an old friend has left some potentially valuable papers unguarded, they will know exactly what to do.