There is little doubt that culture matters for institutions—entities ranging from economics departments to soccer teams spend plenty of time thinking about the cultures they hope to foster—and that culture is also exceedingly hard to measure or define. Regulators now have had a decade since the financial crisis to operationalize their approach to guiding and improving the ethics and culture of the banks they oversee. Understanding what they have chosen to do makes it easier to assess the value of the effort to make cultural transformation an important part of a regulatory program. It also offers lessons to the broader world of public administration, where some agencies, such as environmental regulators, have not made a culture of compliance a priority, while others—securities regulators come to mind—have tried to do more to make certain values stick
David Zaring, Regulating Banking Ethics: A Toolkit, 43 SEATTLE U. L. REV. 555 (2020).