--- title: "Risk Culture: You Better Walk the Walk, Not Just Talk" description: Establishing a risk culture is non-negotiable, but the real key to success is to communicate effectively and positively about abiding by that culture. image: https://blog.goosmannlaw.com/hubfs/Blog_Images/42175754_m.jpg --- [![Goosman Lawfirm](https://blog.goosmannlaw.com/hs-fs/hubfs/Goosmannlaw%20October2017/images/Goosmann_Law_Firm_logo_4C-white.png?width=1250&name=Goosmann_Law_Firm_logo_4C-white.png "Goosman Lawfirm")](http://goosmannlaw.com/) - [COVID-19 Toolbox](https://goosmannlaw.com/covid-19-resource-toolbox/) - Our Team - [Attorneys](https://goosmannlaw.com/attorneys/) - [Non-Attorney Staff](https://http://goosmannlaw.com/non-attorney-staff/) - Practices & Industries - [Practices](https://goosmannlaw.com/practices/) - [Banking & Finance](https://goosmannlaw.com/banking-finance/) - [Bankruptcy, Restructuring & Workouts](https://goosmannlaw.com/bankruptcy-restructuring-workouts/) - [Business](https://goosmannlaw.com/business/) - [Divorce & Family Law](https://goosmannlaw.com/divorce-family-law/) - [Employment](https://goosmannlaw.com/employment-law/) - [Environmental, Health & Safety](https://goosmannlaw.com/health-safety/) - [Estate Planning](https://trustlawcounsel.com) - [Gestational Surrogacy & Adoption](https://goosmannlaw.com/gestational-surrogacy-adoption/) - [International Law](http://goosmannlaw.com/international-law/) - [Litigation / Trial Law](https://goosmannlaw.com/litigation-trial-law/) - [Local Counsel](https://http://goosmannlaw.com/local-counsel/) - [Mergers & Acquisitions](https://goosmannlaw.com/mergers-acquisitions/) - [Rapid Response](https://goosmannlaw.com/rapid-response/) - [Industries](https://goosmannlaw.com/industries/) - [Agribusiness & Cooperatives](https://goosmannlaw.com/agribusiness-cooperatives/) - [Construction](https://goosmannlaw.com/construction/) - [Cyber Law and Telecommunications](https://goosmannlaw.com/cyber-law/) - [Education](https://goosmannlaw.com/education/) - [Health Care](https://goosmannlaw.com/health-care/) - [Manufacturing](https://goosmannlaw.com/manufacturing-law/) - [Multifamily Housing](https://goosmannlaw.com/multifamily-housing-law/) - [Non-Profit & Tax Exempt Organizations](https://goosmannlaw.com/non-profit-law/) - [Real Estate](https://goosmannlaw.com/real-estate/) - [Transportation](https://goosmannlaw.com/transportation/) - [Tribal](https://goosmannlaw.com/tribal/) - Our Firm - [Firm News](https://blog.goosmannlaw.com/firm-news) - Careers - [Attorneys](https://goosmannlaw.com/careers/attorneys/) - [Administration](https://goosmannlaw.com/careers/administration/) - [Internships](https://goosmannlaw.com/careers/internships/) - [Client Testimonials and Results](https://goosmannlaw.com/our-firm/client-testimonials-and-results/) - [Culture, Diversity, and Community](https://http://goosmannlaw.com/our-firm/culture-diversity-and-community/) - [Women-Owned Business](https://goosmannlaw.com/our-firm/women-owned-business/) - [Associations & Memberships](https://goosmannlaw.com/associations-memberships/) - [Firm History](https://goosmannlaw.com/firm-history/) - Blogs - [CEO Law Review](https://blog.goosmannlaw.com/ceo-on-your-side) - [Construction Lawyer](https://blog.goosmannlaw.com/construction-lawyer-on-your-side) - [Cyber Lawyer](https://blog.goosmannlaw.com/cyber-lawyer-on-your-side) - [Deal Maker](https://blog.goosmannlaw.com/deal-maker-on-your-side) - [Divorce Docket](https://blog.goosmannlaw.com/divorce-lawyer-on-your-side) - [Food for Thought](https://blog.goosmannlaw.com/agricultural-lawyer-on-your-side) - [HR Legal Insider](https://blog.goosmannlaw.com/human-resources-on-your-side) - [Law Doc](https://blog.goosmannlaw.com/health-lawyer-on-your-side) - [Paralegal Review](https://blog.goosmannlaw.com/paralegal-review/) - [Real Estate Lawyer](https://blog.goosmannlaw.com/real-estate-lawyer-on-your-side) - [Risky Business](https://blog.goosmannlaw.com/risk-manager-on-your-side) - [The Banker’s Suit](https://blog.goosmannlaw.com/banking-lawyer-on-you-side) - [Trial Law Review](https://blog.goosmannlaw.com/trial-lawyer-on-you-side) - [Trust Law Counsel](https://blog.goosmannlaw.com/estate-planning-laywer-on-your-side) - Resources - [COVID-19 Resource Toolbox](https://goosmannlaw.com/covid-19-resource-toolbox/) - [Podcast](http://podcast.goosmannlaw.com/) - [Videos](https://goosmannlaw.com/videos/) - [FREE eBooks & Tools](https://goosmannlaw.com/free-ebooks-tools/) - Contact Us - [Office Locations](https://goosmannlaw.com/locations/) - [Sioux City Law Firm](https://goosmannlaw.com/locations/sioux-city-law-firm/) - [Sioux Falls Law Firm](https://goosmannlaw.com/locations/sioux-falls-law-firm/) - [Omaha Law Firm](https://goosmannlaw.com/locations/omaha-law-firm/) - [Spirit Lake & Spencer Law Firms](https://goosmannlaw.com/locations/spirit-lake-and-spencer-law-firm/) - [Real Estate Closings Office](https://goosmannlaw.com/locations/real-estate-closing-office/) - [Submit a Testimonial](https://goosmannlaw.com/submit-a-testimonial/) - [Sign Up for Our Newsletter](https://goosmannlaw.com/sign-up-for-our-newsletter/) - [Pay Online](https://goosmannlaw.com/pay-online-3/) - [  (855) 843-4531](tel:855-843-4531) ![](https://blog.goosmannlaw.com/hubfs/Blog_Images/Lockbox%20Lawyer/close-button.png) [tel:855-THE-GLF1](tel:855-THE-GLF1) [Banking](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/banking) # [Risk Culture: You Better Walk the Walk, Not Just Talk](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/risk-culture-you-better-walk-the-walk-not-just-talk) By [Goosmann Law Team](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/author/goosmann-law-team)   |  10, September 2015 [READ NOW](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/risk-culture-you-better-walk-the-walk-not-just-talk) [Read Post](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/risk-culture-you-better-walk-the-walk-not-just-talk#article) [![](https://blog.goosmannlaw.com/hs-fs/hubfs/Logos/Logo1.jpg?width=60&name=Logo1.jpg)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/author/goosmann-law-team) [Goosmann Law Team](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/author/goosmann-law-team)  Tags: [Banking](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/banking) ## ![Regulators are clear. Banking institutions must have strong risk management policies.](https://blog.goosmannlaw.com/hs-fs/hubfs/Blog_Images/42175754_m.jpg?width=674&name=42175754_m.jpg "Regulators are clear. Banking institutions must have strong risk management policies.") ## Improving Risk Culture is a “Necessity.”   --- Regulators are clear. Banking institutions *must* have strong risk management policies.  In fact, at a recent conference, the President of the Federal Reserve Bank of New York said improving risk culture is a “necessity.”  What exactly are those regulators looking for and why aren’t procedures and policies enough? ### 1. Policy and Procedure form the framework. According to the Fed, some of the key metrics that regulators want to see are compliance programs directly dealing with hot buttons like consumer lending, BSA and FATCA; dual or triple monitoring; a specific statement illustrating the institution’s risk appetite; and e-risk systems.  Having these policies in writing and accompanying them with written procedures ensures the first step in tackling the establishment of a strong risk culture. ### 2. Management Needs to Step up the Game. Management must ensure that employees are carrying out risk culture.  Regulators not only want to see policies, they want proof that someone is paying attention to those policies.  Pay careful attention to employee work habits.  Establish monitoring systems.  Do spot checks. Promote positive attitudes about risk culture. Track successes and train on failures—but have consequences for failures.  At the end of the day, regulators want to see that risk culture is effectively communicated from top down.  ### 3. What about the Board? It is clear that the Board is an integral piece of the risk culture puzzle.  Boards should set the tone, and ensure metrics are in place to track the progress of management.  While at times the regulations may be over broad as to the duties placed upon members of a Board, the Fed has indicated that there is light at the end of the tunnel.  Clarity and focus are coming. --- Establishing a risk culture is non-negotiable, but the real key to success is to communicate effectively and positively about abiding by that culture.  Consistent messages and positive direction will make or break employee perceptions about buying into the program. If you’d like to know more about this blog, or banking and finance law, please contact one of our [Goosmann Law Firm](http://goosmannlaw.com/) attorneys at [info@goosmannlaw.com](mailto:info@goosmannlaw.com).  [![CONTACT US](https://no-cache.hubspot.com/cta/default/489404/ec70fe7d-ad02-40c5-93ba-4800375ab6e9.png)](https://cta-redirect.hubspot.com/cta/redirect/489404/ec70fe7d-ad02-40c5-93ba-4800375ab6e9) ### Select Different CTA for each Post from Blog Editor [![New Call-to-action](https://no-cache.hubspot.com/cta/default/489404/a8cefc17-3b9d-4de0-89cd-e60a64752422.png)](https://cta-redirect.hubspot.com/cta/redirect/489404/a8cefc17-3b9d-4de0-89cd-e60a64752422) ### Subscribe Our Blog Thanks for submission!! - Recent - Popular ### Posts by Topic - [Banking (34)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/banking) - [Bankruptcy (26)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/bankruptcy) - [COVID-19 (15)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/covid-19) - [Banking Litigation (12)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/banking-litigation) - [Chapter 11 Bankruptcy (12)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/chapter-11-bankruptcy) - [Subchapter V (9)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/subchapter-v) - [Bankruptcy Court (6)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/bankruptcy-court) - [Student Loan Debt (3)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/student-loan-debt) - [Foreclosure (2)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/foreclosure) - [PPP Loans (2)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/ppp-loans) - [Small Business Owner (2)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/small-business-owner) - [small business (2)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/small-business) - [Agricultural News and Insights (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/agricultural-news-and-insights) - [BNPL (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/bnpl) - [Business Law (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/business-law) - [CARES Act (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/cares-act) - [Chapter 7 Bankruptcy (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/chapter-7-bankruptcy) - [Creditor (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/creditor) - [Cryptocurrency (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/cryptocurrency) - [Deal Gone Bad (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/deal-gone-bad) - [Farm Bankruptcies (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/farm-bankruptcies) - [Farm Forecast (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/farm-forecast) - [Forbearance (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/forbearance) - [Franchise (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/franchise) - [Intellectual Property (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/intellectual-property) - [Judgment (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/judgment) - [Lenders (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/lenders) - [Social Security Benefits (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/social-security-benefits) - [Unpaid Legal Bills (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/unpaid-legal-bills) - [commerical real estate (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/commerical-real-estate) - [evictions (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/evictions) - [liquidation (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/liquidation) - [omaha law firm (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/omaha-law-firm) - [online purchasing (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/online-purchasing) - [subchapter 5 bankruptcy (1)](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/topic/subchapter-5-bankruptcy) DISCLAIMER: The information in this blog post (“post”) is provided for general informational purposes only, and may not reflect the current law in your jurisdiction. By visiting this website, blog, or post you understand that there is no attorney client relationship between you and the Goosmann Law Firm attorneys and website publisher. No information contained in this post should be construed as legal advice from Goosmann Law Firm, PLC, or the individual author, nor is it intended to be a substitute for legal counsel on any subject matter. No reader of this post should act or refrain from acting on the basis of any information included in, or accessible through, this Post without seeking the appropriate legal or other professional advice on the particular facts and circumstances at issue from a lawyer licensed in the recipient’s state, country or other appropriate licensing jurisdiction. #### Let Us Know What You Thought about this Post. Put your Comment Below. [Previous Post](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/so-i-have-a-judgment.-now-what) ##### [So I Have a Judgment. Now What?](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/so-i-have-a-judgment.-now-what) [Next Post](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/foreclosure-or-forbearance-part-i) ##### [Foreclosure or Forbearance: Part I](https://blog.goosmannlaw.com/banking-lawyer-on-you-side/foreclosure-or-forbearance-part-i) ### Contact Info **Sioux City Location** P. 712-226-4000 F. (712) 224-4517 **Sioux Falls Location** P. (605) 371-2000 F. (605) 275-2039 **Omaha Location** P. (402) 280-7648 F. (402) 505-3967 --- [Disclaimer](http://goosmannlaw.com/list-all-blogs/disclaimer/) | [Privacy Policy](http://goosmannlaw.com/privacy-policy/) ### Locations **Sioux City Location** 410 5th Street Sioux City, IA 51101 **Sioux Falls Location** 5010 S. Minnesota Avenue, Suite 100 Sioux Falls, SD 57108 **Omaha Location** Advent Building 17838 Burke Street, Suite 250 Omaha, NE 68118 ![Goosmann](https://blog.goosmannlaw.com/hs-fs/hubfs/Blog_Images/Lockbox%20Lawyer/goosmann-white.png?width=250&name=goosmann-white.png "Goosmann") Goosmann Law Firm is a FULL SERVICE LAW FIRM with locations in Sioux City, Iowa, Sioux Falls, South Dakota, and Omaha, Nebraska. Goosmann Law attorneys are licensed to practice in Iowa, Nebraska, South Dakota, and North Dakota. Their attorney team's practices and industries include but are not limited to Agribusiness and Cooperatives, Banking and Finance, Bankruptcy, Restructuring and Workouts, Business, Construction, Cyber Law and Telecommunications, Divorce and Family Law, Education, Employment, Environmental Health and Safety, Gestational Surrogacy and Adoption, Health Care, Litigation and Trial Law, Manufacturing, Mergers and Acquisitions, Municipal, Nonprofit and Tax Exempt Organizations, Real Estate, and Transportation, Tribal, Wills, Trusts, Estate Planning, and Probate Law. Goosmann © Copyright 2017