Saturday, August 4, 2012

The GFC Was More Complex Than Failed Regulation And Greed

In responding to the Global Financial Crisis, Harvard historian and leading public intellectual Niall Ferguson recently wrote; "Better education, not over-regulation, is what is needed to repair the damage done to our financial system. Banking will never be God's work. But we can surely make it less like the Devil's." According to Ferguson business education needs urgently to be reformed so future bankers learn to strive for more than just the "maximisation of shareholder value". Ferguson is one of many influential thinkers who subscribe to the view that the GFC can largely be attributed to a combination of a failure of regulation and/or a culture of greed. But the GFC is not the only recent example of systemic business failure. In the banking sector they just keep on coming and then there are human induced environmental crises such as the Deepwater Horizon oil platform disaster. But is more regulation and different education the solution?

We agree that there is a problem in the business schools. The managerial theories and methods taught throughout the world are largely predicated on the possibility of control. These are increasingly inappropriate to a business environment which many argue is becoming more uncertain. While we have always had to live with highly unpredictable events like natural disasters, today's uncertainty increasingly results from human and business activity. It includes climate change, terrorism, food security, pandemics and systemic failures in financial systems; the list of significant, realised and potential disruptions with global scope grows year on year. What is significant about human induced uncertainty is that, to an even greater degree than with natural disasters, it is always the case that someone making an alternative choice along the way could have prevented it. It appears as if this uncertainty should be able to be controlled. But this is an illusion. Unfortunately the illusion is so pervasive that it forms the backdrop to most of the systems we have built to manage it - our risk and disaster management systems. It also explains why many see more regulation as the solution. The presumption is that with tight enough frameworks and sufficient oversight we will ensure only the right decisions are made.

Uncertainty is the basis for business risk. Indeed, the new risk standard, ISO 31000 makes this explicit by defining risk as "the effect of uncertainty on objectives". On this basis, the capacity of an organization to manage uncertainty should be at the centre of all risk and compliance management. It often is, but in a perverse way. This is illustrated by a recent study undertaken into the implicit 'theories' which guide policy recommendations and the actions of risk professionals and organizational decision makers. What this study reveals is the pervasive nature of assumptions which both fail to manage down uncertainty and worse, potentially reduce organizational capacity to respond effectively. This is because most risk managers actually advocate approaches which assume the possibility of certainty not the ubiquity of uncertainty.

There was a big difference between the 'theories' held by the following key professional groups; auditors, actuaries, compliance professionals - the professions which populate what Michael Power has called the newly minted ' risk industry' - and their key stakeholders the strategic and operational managers. Auditors were characterized by an 'Absolute Values' world view, where there are right and wrong ways to do things no matter what the context. Actuaries demonstrated the most mono-dimensional approach labeled 'Hyper-rational'. Such an approach represents a commitment to the assumption that uncertainty can be tamed by rational analysis using past data and formal models. This group was distinctly risk averse. Particularly concerning was the evidence in the study that advocates of one approach often reject alternative approaches, seeing theirs as more universal rather than appropriate to a limited range of risk situations.

The good news is that the strategic managers we interviewed reflected awareness that uncertainty is pervasive and that it is often not usefully approached through detailed prior analysis but rather by a responsive or resilience based approach - maintaining a capacity to respond flexibly and quickly. The risk professionals, by contrast, brought approaches invested heavily in control based thinking - appropriate for some risks but not necessarily those that often threaten the very existence of the firm or that have consequences for industry, national or even global stability. These are often labelled the low probability high impact risks which no-one in the risk management industry seems to know quite how to deal with. They involve complex chains of causality where the decisions of many conspire to bring about the presenting risk but which could not be foreseen by anyone as it involved cascades of chance, each one of which would have appeared as insignificant in and of itself.

The strategic managers view is hat there is little value to be gained by prior analysis or planning on the grounds that risk events are unpredictable - or at least the risk that catches you out will be the one you did not anticipate. Those who enacted this theory also placed importance on personal values and beliefs and showed a high level of willingness to 'back themselves' in handling the situation. On the face of it, the responsive theory appears appropriate to a context with high levels of uncertainty. These managers advocate maximizing the organization or individual response capability without pre-committing resources to particular sources of risk. The weakness of this approach is that it can involve managers assuming too much about their capacity to deal with the unexpected. We have seen evidence of this in the institutional response to natural disasters and it is evident, too, in BP's response to the Deepwater Horizon disaster. Research into handling of crises, such as natural disasters or military skirmishes, shows that decision makers in the field have a limited capacity to process the complex, incomplete, and often ambiguous or contradictory information typical of rapidly unfolding situations. They easily succumb to cognitive overload. Cognitive researchers like Jonah Lehrer and Nobel Laureate, Daniel Kahneman, Author of Thinking, Fast and Slow, have shown that decision makers make poor decisions under such circumstances unless the situation is sufficiently similar to those with which they have had prior experience therefore allowing them to rapidly construct a response framework on the run. Closer analysis also suggests that there are two variants of the responsive theory. The most dangerous, but unfortunately the one which is most often reflected in the approach to leadership advanced by our business schools, and very evident in the endless case studies of the celebrity CEO, is an egotistic one where the capacity to do whatever it takes is seen as located within the individual - the 'manager as hero'. The problem this suggests is not one of greed so much as of executives falling victim to their own hubris, a hubris which current executive remuneration would seem to fuel.

Other advocates of the 'Responsive Approach' placed greater emphasis on building the agency of others. This approach is about building a deep capacity within the culture - one in which everyone is continually scanning for risks and acting to mitigate them and also ready and able to collaborate and learn in flexible ways to deal with a crisis. This carries fewer downsides as the problem of information overload is dealt with by the fact that there are many minds to share the load and limited opportunity for group-think. This later variant also harnesses the diversity of experience in the organization and a deeper pool of relevant responses all combined through a capacity to learn by doing.

In conclusion then, no one approach to risk is well placed to deal with the complex risk environments that currently confront corporations both large and small. That different theories of risk become associated with particular roles presents a point of cultural division, and introduces a barriers to an organization's capacity to respond effectively to risk, even though it has within it a wide range of alternative perspectives. More concerning is that the various risk professions have developed a set of skills and dispositions for dealing with particular types of risk - often not the most dangerous - but have a tendency to over generalise the applicability of their approach, seeing it as the one which should drive organizational processes. This leads us to suggest that the problem of maintaining effective governance of an organization in the face of uncertainty is at least in no small part a cultural challenge, rather than one of preparedness, resourcing, skill availability, education or procedural adequacy - or even more simplistically - of individual motivation such as greed. It is therefore imperative that policymakers, regulators, central bankers and financial professionals understand the nature of their risk culture and how it is likely to affect their ability to deal with risk and uncertainty.


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Dr Chris Goldspink is an Executive Director of Sydney Australia based research and consulting firm Incept Labs http://www.inceptlabs.com.au Incept Labs helps SMEs, large corporates and Government deal with uncertainty in current and future environments by providing targeted research and supporting innovation, risk management, change and quality governance.


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