How can we accelerate the rebuilding of trustworthiness and confidence in financial services?

We believe it necessary to have a highly inclusive and consensus-based approach to developing and implementing the solution. Anything else would not achieve the buy-in necessary and therefore would not represent a sustainable solution. It follows that we will need to have many people and organisations involved and these participants will be required to participate on a voluntary basis.

It is therefore wholly appropriate that we show appreciation for the contributions by all involved and properly attribute their highly valuable and much-appreciated input. This in itself will encourage the participation of others; and that’s a vital thing to do for a book that will be refreshed each year and seek input from an ever-increasing community of participants.

We will be fully recognising all support given whether that be by way of written content, operational support, project management support, technical input, sponsorship, guidance and so on.

We will ensure that the book will be seen to be a team effort because that’s exactly what the whole initiative is.

This chapter will set out what we see to be the critical success factors necessary to create a sustainable solution, namely:

• Inclusivity is key; because it is the entire sector that needs to change so all aspects of it should be involved in determining what needs to change and how that change should happen. It follows that market participants, politicians, regulators, relevant government departments, think-tanks, campaign groups, trade bodies, professional associations, members of the public and so on should all be invited to participate in the development and implementation of the solution;

• The approach taken should be collaborative, co-operative, collegiate and consensus-based; because it makes sense for all involved to feel comfortable working together in a constructive and non-partisan way. Only a solution that has a broad base of support is likely to succeed in a sustained manner. All participants are on the same side; and against the trust deficit and the causes of the trust deficit; so, it should feel that way;

• Remedies must be future-gazing; we need to look forward. Whilst we know we can learn from the past and we know the failings of the past will guide how we move forward, the “time to mourn” is over. It is all about the future now and we must look into the future with a sense of possibility, positivity and promise;

• The focus should definitely include the pensions and investments sector; because according to the Office of National Statistics, the UK is experiencing the lowest savings ratio since records began way back in 1963 and surely the trust deficit and the disengagement it creates must be a part of the problem. Furthermore, it is known that pension policymakers and financial regulators around the world are particularly concerned with what can be done to help avoid mass pensioner poverty in the future. Rebuilding trust is clearly part of that solution so the “pension crisis” and “the savings gap” are the most obvious burning platforms to be resolved;

• A steady pace to reform will be crucial; because whilst everybody would like the trust deficit to be solved quickly it would be wholly unrealistic to expect that to happen. The problem is too big and too complex for a quick fix. This is going to be a marathon, not a sprint so it is vital that we build a framework for finance reform that has longevity and adaptability hard-wired in to the design;

• We must accept that the challenge is complex, multi-faceted and has many root causes; we will need to develop “a whole-system solution” because we are dealing with “a whole-system problem.”

This chapter will explain that our work goes far beyond just describing the problem and considering how it can be solved; it actually moves onto initiating and managing change.

This approach requires a strategy for driving change; and the Transparency Task Force has had an effective strategy for driving change that we have been using to very good effect since we began to operate in May 2015.

The Transparency Task Force strategy for driving change is all about bringing together the thinking of two very important groups:

 – #1, those with a sense of passion & purpose about what needs to change; such as the members of the Transparency Task Force Special Interest Groups and the Transparency Task Force Ambassadors

– #2, those with the power & position to make change happen; such as the politicians, policymakers, regulators, leaders of key trade bodies and professional associations, leaders of key commercial organisations and so on.

The book and the project as a whole are an embodiment of that strategy for driving change.

To attract and engage with the people necessary for our strategy for driving change to work we are doing 3 things:

1. Drawing on the vast existing network of Transparency Task Force members; including the 725 members of our 22 Special Interest Groups and our 117 Ambassadors. This network has been carefully built over the last 4 years and continues to grow quickly.

To see the members of our 22 SIGS you can download the spreadsheet available on this page: 

https://new.transparencytaskforce.org/teams-of-volunteers/

To see the Transparency Task Force Ambassadors, see this page:

https://new.transparencytaskforce.org/ttf-ambassadors/

2. Running special meetings around the world;

These special meetings are already underway, and they are proving to be highly successful. As well as strengthening the relationships we have with our existing members around the world who participate in the meetings we are also actively meeting new people and recruiting new members including individuals that will make excellent subject-matter experts and thereby play a key role in providing thought-leadership content for the book as explained later; and also, members of the Scientific Committee as explained later.

The special meetings are taking place in the major financial centres around the world. The slide below shows the programme of meetings for 2019; a similar programme will be created for 2020 and each year thereafter – the project will continue to evolve and build momentum year after year; this will be a marathon not a sprint. 

Our special meetings are dedicated to the question:

 “How can we accelerate the rebuilding of trust and confidence in financial services?”

In effect, we are using that question to initiate and facilitate a global conversation about the Trust Deficit and what can be done about it. A great deal of thought has gone into crafting that question:

• The question is very deliberately future-orientated; we must learn from the past but not live in it – the project is not about apportioning blame

• The question is very deliberately solution-orientated; we avoid the temptation to just pose the question – we want real, workable answers

• The question is very deliberately palatable to all stakeholders such as politicians, policymakers, academics, regulators, thought-leaders, subject-matter experts, progressive market participants, trade bodies, professional associations and so on
• The question is very deliberately able to function as a gateway through which dialogue can move into the underlying causes of the trust deficit. This is extremely important because only by dealing with the underlying causes of the trust deficit can we hope to truly cure the problem as opposed to just treating the symptoms.

As well as helping to attract new participants our meetings are already proving highly valuable as a means through which we can evolve and stress-test our thinking. At each meeting we articulate the latest iteration of our plan but far more importantly we attentively, actively and authentically listen to the open discussion and debate that we facilitate; encouraging consensus-building as we go. We are in effect helping to “crowd-source” the thought leadership that is needed.

We are truly delighted by the quality of the input already provided and how our solution-orientated collective consciousness is taking shape; our meetings are working very well.

3. Defining and reaching out to the 1,000 most influential people around the world that in effect govern the way the financial system works;

These individuals are the “power and position” group for whom the book has been especially written; they will be individually told that as the initiative advances. They are key actors in the change management process that we are driving; they hold the keys to the door through which the financial services industry needs to pass. Without their active engagement and support the change we want to see cannot happen.

The 1,000 will include politicians, policymakers, regulators, the leaders of the major trade bodies, the leaders of the professional associations and the leaders of the major commercial organisations be they banks, asset managers, insurers and so on.

The book is a clarion call for engagement to that group. We will be personally reaching out to each and every one of them to invite them into dialogue – this is happening already, and it is working.

The more of the 1,000 we succesfully engage with, the easier it will be to get engagement from others because there will be a “tipping point dynamic” whereby the more influential people that get involved the more compelling it will be for others to follow.

We do not need all 1,000 to get involved; we deem that if we get supportive engagement from 15% of the 1,000 we will be able to drive transformational change because we will be able to aggregate and multiply their individual and collective influence.

We believe that if we are able to mobilise just 15% of “those with the power and position” we can make a real and lasting difference. Note that our thinking around the “15%” has been inspired by the work of Gary Haugen of the International Justice Mission who observes informally that most public justice systems around the world follow a 15-70-15 principle. 

We are applying that principle in the belief that:

• 15% of the 1,000 will be inherently apathetic towards the idea of system change, so they will not engage regardless of what we do
• 15% of the 1,000 will be highly predisposed to engage; they are individuals that will help lead the charge. We will be seeking to engage with the 15% of the 1,000 that have latent potential to want to be part of the solution but may currently be passive in the context of driving finance reform (despite their power and position to do so). We do not believe they will need to be persuaded i.e. they will already have a predisposition to want to help; they just need to be shown how they can.
• 70% are influenceable and will be responsive over time to what we and the “early adopter” 15% think and do. 

Over time therefore, we have the potential to mobilise 15% + 70% = 85%

If we manage to do that it will mean we have 150 powerful and well-positioned people around the world that can act as catalytic agents for change; thereby unlocking a treasure-chest of powerful potential goodwill through the 70%

As explained later, the individuals within the 1,000 will be updated year by year as part of a systematic approach to ensure we harness the full potential power of “those who have the power and position.” 

The 1,000 will include leaders of organisations such as these in the UK:

Regulators/Government-Related –

• The Financial Conduct Authority
• The Pensions Regulator
• The Department for Work and Pensions
• The Competition & Markets Authority
• The Bank of England
• The Financial Reporting Council;

Professional Associations such as –

• The Institute of Actuaries
• The Pensions Management Institute
• The Institute of Chartered Accountants in England and Wales
• The Chartered Financial Analysts Institute
• The Personal Finance Society

…and many more;​

• The Pensions and Lifetime Savings Association

• The Investment Association
• The Tax Incentivised Savings Association
• UK Finance

…and many more;

Civil Society Groups such as –

• The Royal Society of Arts
• The Friends Provident Foundation

…and many more;

The 1,000 will also include UK Parliamentarians with a known interest in the financial services sector such as:

• Baroness Ros Altmann
• Tom Tugendhat MBE MP
• Frank Field MP
• Lord Cromwell
• Lord Lindsay
• Lord Turner
• Lord Lamont
• Lord Lawson
• Alistair Darling
• Gordon Brown MP

…and many more;

The corresponding individuals/organisations in other countries around the world will be included; Getting to 1,000 is therefore not an unachievable figure because of the truly international nature of our project.

Furthermore, we will also be reaching out to leaders of major international organisations such as:

• The IMF
• The OECD
• The World Bank
• The Bretton Woods Committee
• The United Nations Global Compact

…this process has already started, and we believe that having the active support of just one of these organisations will be immensely significant.

The names, job titles and organisations of the 1,000 will be listed in the Appendix; and please note that we will be seeking for at least 40% of the 1,000 to be female because we are determined to help ensure the female perspective is properly included.

The book and the project as a whole are an embodiment of the way in which we will bring together the thinking of the “passion and purpose” group and the “power and position” group. By doing so we are building an international community of all types of stakeholders willing and able to work on the trust deficit in a planned and coordinated manner.

The Problem Statement will give an Evidence-Based account of what the Trust Deficit is, its causes and consequences.

The characteristics of the financial services sector and the behaviour within it that leads to distrust include:

• Hidden and excessive costs
• Hidden and excessive risks
• Opportunistic opacity
• Opportunistic obfuscation
• Short-termism
• Insufficient client-centricity
• Scams and scandals
• Regulatory capture
• Irresponsible reward systems
• A ‘profit before principles’ mindset
• A ‘money before morals’ mindset
• Conflicts and misalignments of interest
• Excessive lending and gearing
• Disingenuous communications
• Financial instability
• Weak governance
• A lack of market integrity
• A lack of values-based leadership
• Malpractice, malfeasance, misconduct and miss-selling

Clearly, there are many causes to the trust deficit and the causes are complex and interconnected. Dealing with any of the issues in isolation won’t work; we believe that only a whole-system solution can fix a whole-system problem; and the solution needs to be both systemic and systematic.

The Vision Statement is where we “Dare to dream” of what it would be like if there were to be a transparent, truthful and trustworthy financial services sector. In this chapter we will articulate a deliberately utopian view that will help us envision what it will mean for society if trust and confidence in financial services was fully restored; we think it would make a profoundly positive difference.

By showing the comparison and contrast between the Problem Statement in Chapter 4 and the Vision Statement in Chapter 5 will give the book and the project as a whole a natural sense of direction and momentum. 

The project as a whole is about creating a framework for finance reform; and at the heart of that framework for finance reform are the Finance Development Goals (FDGs).

Each of Chapters 6 to 17 will be dedicated to a Finance Development Goal and within each of those chapters there will also be Formal Recommendations for Change.

There are 12 Finance Development Goals (FDGs) and each one is focused on a root cause of the trust deficit. Each FDG is to be developed by the subject-matter experts from around the world that we are recruiting into the project; there will be a separate group of subject-matter experts for each FDG (and there will be some subject-matter experts involved in more than one FDG).

Here’s a list of the FDGs with an accompanying quotation to indicate the topic they cover:

VIRTUOUS LEADERSHIP

“The supreme quality for leadership is unquestionably integrity. Without it, no real success is possible, no matter whether it is on a section gang, a football field, in an army, or in an office.” 

 – Dwight D. Eisenhower

 This FDG covers topics such as:

• Virtues-based and values-based leadership
• Why we must deal with the “leader’s dilemma” problem, to unlock the potential for major transformational change
• Moral Quotient
• The insights of Adam Smith’s work on moral sentiments
• The insights of Alexandre Havard on virtuous leadership

CREATE A CLIENT-CENTRIC CULTURE

“Ethics is knowing the difference between what you have a right to do and what is right to do.”

 – Potter Stewart

 This FDG covers topics such as:

• Competence
• Ethics
• Values
• Professionalism 
• “Principle before profit”
• “Morals before money”
• Fairness
• The need for a cultural transfusion
• Values-based leadership
• Why we must deal with the “leader’s dilemma” problem, to unlock the potential for major transformational change
• The use of Moral Quotient
• Diversity and Gender
• Mandating for higher standards of conduct
• The effective use of oaths, codes of conduct, standards boards and pledges 
• Trade Bodies and Professional Associations to realise their potential role as cultural architects
• Individual, Organisational and Market Integrity
• Encourage diversity of ownership structures such as Mutuals, Coops and FairShare
• Why it is so important that individuals think for themselves and don’t “follow the herd” despite the potential career risk consequences of doing so
• Having metrics to measure, monitor and manage trust

HARNESS THE TRANSFORMATIONAL POWER OF TRANSPARENCY

“Sunlight is the best of disinfectants; electric light the most efficient policeman”

 – Justice Louis Brandeis

This FDG covers topics such as:

• The need for transparency on costs & charges
• The need for transparency on any risks the client may be exposed to
• The need for transparency on performance metrics
• The need for transparency on the agenda and motivations of actors
• The development of a Global Transparency Index
• Why is transparency in and of itself necessary but not sufficient?
• What are the limitations and potential pitfalls of having too much of “the wrong type of transparency” and “unconstrained standardisation”?
• Decision-making being underpinned by relevent and reliable data
• Benchmarks and indices being free of bias and distortion
• Credit Rating Agencies being fit for purpose

HARNESS THE TRANSFORMATIONAL POWER OF TECHNOLOGY

“Computers are useless. They can only give you answers.”

 – Pablo Picasso

This FDG covers topics such as:

• How “technology is a friend of transparency” and why it should be fully utilised
• Harnessing the inherent advantages and efficiencies provided by technology 
• The enormous potential for Fintech, Blockchain, Smart Contracts, AI, greater Interoperability and evolutions thereof to radically improve the integrity of the system
• The scope for technology to reduce operating friction and the sector’s higher-than necessary costs, thereby protecting consumers from excessive friction costs that worsen outcomes e.g. they corrode investment returns
• Making good use of technology to provide person-specific data; for example, through data dashboards dealing with pensions and investments contextualised with individual-specific planning goals
• The potential risks of over-reliance on technology and inadvertently absorbing systemic risks into the ecosystem; particularly through inadequate cyber security

GOVERN WELL

“Good governance is the art of putting wise thought into prudent action in a way that advances the well-being of those governed.” 

 – Diane Kalen-Sukra

This FDG covers topics such as: 

• Accountability
• Compliance
• Regulatory reform
• Firm and consistent enforcement of the rules; with adverse publicity for rule-breakers, thereby creating an effective deterrent 
• The vital role of effective accounting, auditing, financial reporting and credit rating
• Custodianship
• Stewardship of capital; such that the world’s capital markets can operate as a force for good
• Encouraging greater inclusion and diversity
• Developing an “International Regulatory Master Plan”

DESIGN PRODUCTS THAT DELIVER

“Good design is like a refrigerator—when it works, no one notices, but when it doesn’t, it sure stinks.”

 – Irene Au

This FDG covers topics such as:

• Products to be engineered to a high standard
• Products to be fit for purpose
• Products to be free of fundamental flaws
• Product Accreditation
• Transparency Accreditation
• Providing value for money

COMMUNICATE AUTHENTICALLY

“The single biggest problem in communication is the illusion that it has taken place.”

 – George Bernard Shaw

This FDG covers topics such as:

• Presenting data and information clearly and intelligibly
• Encouraging greater consumer engagement wherever possible
• Seek to minimise the amplification of adverse publicity through active PR and Reputation Management
• Asymmetries of information to be minimised
• Use of Simple Benefit Statements
• Asymmetries of information to be minimised
• Use of Simple Benefit Statements
• Communicating with integrity, credibility and authenticity

ACT WITH PURPOSEFULNESS

“When you are inspired by some great purpose, some extraordinary projects, all your thoughts break their bonds; your mind transcends limitations; your consciousness expands in every direction; and you find yourself in a great new and wonderful world. Dormant forces, faculties and talents become alive and you discover yourself to be a greater person by far than you ever dreamed yourself to be.”

 – Patanjali

This FDG covers topics such as:

• Impact Investing
• Sustainability
• Climate Change
• ESG
• Socially Responsible Investing
• Social Finance
• Social Stock Exchanges

INCENTIVISE RESPONSIBLY

“Show me the incentives and I’ll show you the outcome”

 – Charlie Munger, Berkshire Hathaway

This FDG covers topics such as:

• Responsible Reward
• Fully account for human nature and “what’s in it for me?” mindsets
• Manage out conflicts of interest where possible; fully disclose where not
• Alignment of Interests; dealing with the “Principal-Agent Problem.”
• Use fee and payment structures that align interests wherever possible
• Alignment of goals, returns and risks 
• Adopt Fiduciary Duty, Duty of Care and Best Interests thinking

STABILISE THE ECOSYSTEM

“Remember when nurses, carers, teachers and students crashed the stock market, wiped out banks, took billions in bonuses and paid no tax? No, me neither.”

 – Fuad Alakbarov

This FDG covers topics such as:

• Minimising the risk of systemic market failures that lead to severe shocks to the system

PROTECT CONSUMERS FROM HARM

“To not do what you can to protect someone, that’s cowardly.”

 – Jodi Lynn Anderson

This FDG covers topics such as:

• Minimise the risk of fraud and scams
• Properly support and care for those that have been scammed
• Be alert to policy failures that expose consumers to risk of harm e.g. pension freedoms
• Financial Consumers’ Bill of Rights
• Use litigation to provide redress and proactively drive changes in market practice
• Encourage and facilitate worry-free whistleblowing
• Safeguard data integrity
• Develop resilient and robust Cyber Security
• Get the administration right – strive for operational and administrative excellence
• Proactively seek to repair damage when it is done; problems will inevitably arise; and mistakes will inevitably happen
• The vital role that can be played by more and better financial education to boost financial literacy for consumers, mitigate the risks associated with asymmetries of information and help prevent miss-selling to the vulnerable

MANAGE RISK

“Not taking risks one doesn’t understand is often the best form of risk management”

 – Raghuram G. Rajan

This FDG covers topics such as:

• The need for transparency on any risks the client may be exposed to
• The need for transparency on performance metrics
• The need for transparency on the agenda and motivationsof actors

…………………………………..

Each of these FDG Chapters will be a collection of thought-leadership essays written by relevent subject-matter experts.

Their essays will be a response to a tailored FDG-specific question. Here are some examples, showing that the stem of the question is the same for each FDG, but the ending is adapted according to which FDG is being dealt with:

• “How can we accelerate the rebuilding of trust and confidence in financial services through greater transparency?
• “How can we accelerate the rebuilding of trust and confidence in financial services through creating a client-centric culture?
• “How can we accelerate the rebuilding of trust and confidence in financial services through governing well?” and so on.

In addition, each of these FDG chapters will also have a set of Formal Recommendations written collaboratively by members of The Scientific Committee. The Formal Recommendations will be addressed to the Special 1,000 and they will be invited to respond to the recommendations i.e, they will be invited to report on their thoughts about the recommendations in the following year’s edition.

Through the reporting back process, we will be able to shine a bright light on who has done what in response to the formal recommendations made by the Scientific Committee; and thereby create a sense of transparency, responsibility and accountability amongst the 1,000. It is this process of engagement that will mean the Formal Recommendations are much more than just sterile suggestions; they will be fertile dialogue that will yield fruit in the form of change.

The ongoing interaction and engagement between those with “the passion and purpose for change” and those with the “power and position to make change possible” through the writing, reading and responding to the thought leadership essays by the subject-matter experts and the formal recommendations by the Scientific Committee will be the engine that drives the change that is needed.

The Scientific Committee will be carefully selected; it will be a “Dream Team” of highly respected individuals; and acting as a group they will be too credible to be ignored by the 1,000 we are seeking to engage with. The Scientific Committee will have technical and governance oversight of the book and the project as a whole.

The Conclusions and Next Steps chapter will consolidate the overall message from the book which is that through the application of a systematic and comprehensive approach to driving change we can co-create a solution that “acts like a sat-nav for finance reform,” always asking:

• Where are we now?
• Where do we want to get to?
• What is the best way to get there?

We will also build momentum for creating the following year’s edition because in this chapter we will explain the that:

• Each year there will be an updated edition with a refreshed set of Formal Recommendations
• The subject-matter experts already involved with the project are invited to submit new essays to express updates and advances in their thought leadership
• New subject-matter experts are invited to submit thought leadership essays to increase the breadth and the depth of the experience and wisdom being fed into the project
• The Special 1,000 are invited to respond to the Formal Recommendations they have been given; the readers of the book will thereby become the writers of the book over time i.e. an osmosis-like process will be encouraged to blend togethor the thinking of “those with a sense of passion and purpose for the change that is needed” and “those with the power and position to make change possible”
• We want suggestions for new additions to the Special 1,000. The new additions will refresh the Special 1,000 each year; we will be selecting out those that do not wish to engage, and we will be replacing them with those that do. This way there will only ever be 1,000 in the Special 1,000 and year by year the 1,000 will become an increasingly engaged, participative and supportive group; they will move from being the targets of our collective effort to becoming active contributors to our collective effort.