Tone from the middle (not top) drives compliance

Tone from the top is a catchy phrase, but Client Focused Reform, FSRA’s focus on advisor compliance and OSFI’s focus on conduct risk underline that ultimately compliant behaviour is driven by the individual. To truly shape a compliance culture you need to know your advisor, your staff and your manager’s data to guide them to compliant behaviour. The focus needs to be on building a true supervisory file which breaks down internal data silos and provides quantifiable measures to allow organizations to adopt a risk-based approach to supervision to manage their legal, regulatory and reputational risk.