I have worked closely with RCSA. I have a pretty broad view where we are from a quality standpoint.
It is mostly trash and too high level. Where is audit? Better question, where is Wells Fargo Compliance?
This bank will be back in the news within 4 years. This isn’t risk management. I don’t know what to call it. Investment in a process that results in deterrence?
It's nothing more than grandstanding with a dash of check-the-box. Every evaluation of risk is qualitative judgment based, very little actual calculation of probability-adjusted cost of a particular risk. And they don't even think about the cost-reward tradeoff of what it takes to mitigate a particular risk.
TLDR: It's total bullsh-t.
Yeah, I don't think you know cr-p. All RCSA stuff I've been through is like a rectal exam. No stones unturned.
Hate to disagree with a perfectly valid observation. The whole point of RCSA is to match the framework of other large banks, not to actually do the right thing.
This company was a better place to work when leaders were at constant risk of being hauled in front of congress. They actually had to give some thought to recruitment and retention then. The current execs seem to thrive on how miserable they can make their employees. I personally look forward to the next scandal, hopefully it forces a little more humility