A Function in Transition How the Chief Compliance Officer role is transforming across Financial Services R604008-rr0063- CCO in FS v15.indd 1 14/04/2016 10:34:02 2 Contents The New Face of Compliance: Changing Talent Requirements in Financial Services 3 A new wave of Chief Compliance Officers have entered financial services 4 While CCOs are often drawn from law firms and the regulatory realm, cross-pollination between financial services sectors remains a rarity 5 Banking CCOs: Rise of the broad-minded business partner 6 Asset Management CCOs: Compliance begins to come of age 7 Insurance CCOs: still early days 8 Priorities are changing… with strong implications for talent 9 What’s next for financial Services CCOs? 10 Methodology 11 R604008-rr0063- CCO in FS v15.indd 2 14/04/2016 10:34:02 3 The New Face of Compliance: Changing Talent Requirements in Financial Services As regulatory pressures intensify around the world, BY SECTOR: the financial services sector is seizing the initiative by Banking: Rise of the broad-minded business boosting investment in its compliance functions. The partner. Banking CCOs are increasingly focused impact of increased regulation on the sector is well on driving cultural change, rather than simply documented. Less clear, though, are the implications managing their institutions’ approach to for compliance roles and talent requirements. regulation. To better discuss the changing role of compliance, Asset management: Compliance begins to Russell Reynolds Associates has analyzed the profiles come of age. We are witnessing an interesting of more than 72 Chief Compliance Officers (CCOs) in trend at a number of large to mid-sized asset banking, insurance and asset management. managers, wherein the compliance function Our research shows increased investment in is being separated from Legal (where it had compliance functions across each of these sectors. It historically resided). also reveals a major shift in the composition of these Insurance: Still early days. Compliance in the functions, with a surge of external appointments to key insurance sector is still in its infancy, with roles over the last two years. relatively few dedicated CCOs. CHIEF COMPLIANCE OFFICERS IN FINANCIAL SERVICES: MATURITY CURVE Banking CCOs: Broad scope and business focus Asset Management CCOs: Closely tied to legal, traditional compliance Insurance CCOs: Few dedicated CCOs New Improving Mature Aging R604008-rr0063- CCO in FS v15.indd 3 14/04/2016 10:34:02 4 A new wave of Chief Compliance Officers have entered financial services Seven years post-financial crisis, the compliance These findings point us in two key directions. First, function in financial services remains under heavy financial services companies are deeply interested in scrutiny. For all of the attention that has been paid overhauling the compliance function; second, they are to optimizing compliance, we believe this much- dissatisfied with their own compliance talent pools. examined function has yet to reach full maturity. We see a collective search for a more change-oriented, Nowhere is this more evident than in the startling risk-savvy compliance function, with companies turnover of Chief Compliance Officers in the last two clearly signaling the need for a visible shift by bringing years. 35% of the companies we examined appointed in outside executives. This trend is as fascinating as a new CCO after 2013, and 43% of these hires were it is unsustainable – organizations will be eventually external. challenged to develop richer compliance talent internally. SHARE OF CURRENT CCOS APPOINTED IN AND aftER 2013 Financial services CCOs are disproportionately Banking 60% recent appointees... Global Asset 40% Management Firms Insurance 25% SHARE OF INTERNAL VS. EXTERNAL APPOINTMENts OF CURRENT CCOS …and to a striking degree, Global Asset are external hires Banking Management Firms Insurance 35% 46% 44% 54% 56% 65% Internal External R604008-rr0063- CCO in FS v15.indd 4 14/04/2016 10:34:02 5 While CCOs are often drawn from law firms and the regulatory realm, cross-pollination between financial services sectors remains a rarity Our research shows that banking, insurance and converge combined with the increased maturity of the asset management CCOs tend to have backgrounds talent pool for senior compliance leaders, we expect to dominated by their current sector, with very limited see more movement between the three sectors. movement between these sectors. Oddly, all three groups of firms are more willing to hire from law firms and regulators, reflecting a relatively rigid view of “feeder” roles into the CCO role. However, as regulation for banks, asset managers and insurance companies INDUstrY EXPERIENCE OF CCOs IN BANKING AND ASSET MANAGEMENT 0% Asset Management 82% 10% 72% Banking (Investment or Commercial) 15% 25% 0% Insurance 3% 80% 29% Law firm 24% 30% 28% Regulator/ Government 38% 20% 14% Banking Consulting / Accounting 9% Asset Management Firm 20% Insurance R604008-rr0063- CCO in FS v15.indd 5 14/04/2016 10:34:03 6 Banking CCOs: Rise of the broad-minded business partner The compliance function in banking is, compared to Gone are the days of principally legal and compliance other financial services sectors, further along the executives nabbing the top job in the compliance lifecycle curve. In practical terms, this means that function – For instance, before 2013, 55% of appointees banking CCOs are increasingly focused on driving had legal experience and 45% had compliance cultural change, rather than simply managing their experience. Since 2013 just 29% of appointees had institutions’ approach to regulation. Historically, the legal experience and 24% had compliance experience. compliance function was a world where the least Filling the gap were broader-focused appointees charismatic sat, the ones who knew process but did from consulting, risk and audit. This new breed of not have to interface on a regular basis with business appointees would be well-positioned to contextualize leaders or regulators. However, changes in banking compliance (and the associated cultural change) in regulation has thrust three crucial needs upon banks the wider picture of the organization. We see the ability all at once – the need for leadership, the need for an to think broadly in the overall functional profiles of advanced understanding of transactions within the current banking CCOs –fully 42% of recent appointees digital realm, and the ability to manage regulators on a came from “middle office” roles such as operational day to day basis. All these means a cry for a new type risk, internal audit, as well as external consulting firms, of compliance officer. where competencies such as defining compliance As a result of these changes, we see this shift strategy, financial discipline, change management and manifested in the functional leadership backgrounds building credibility with regulators, were integral parts of CCOs appointed before 2013 versus those in the last of the role. few years. NotaBLE CHANGES IN Most RECENTLY FUNctIONAL LEADERSHIP roLES HELD HELD roLE PRIOR to APPOINTMENT for across THE ENTIRE CAREER BY CURRENT CCO BANKING CCOs 55% Before 2013 and Legal 2013 a erwards 29% Compliance 45% Compliance 45% 18% 24% Regulator/ 36% Before 2013 and Government 18% 2013 Internal a erwards 36% Audit Sales/Trading 9% 18% 12% CEO/Business 27% Leadership Before 2013 and 18% Consulting/ 2013 a erwards 18% Big 4 Internal Audit Accounting 18% 0% 12% 18% Risk 18% Before 2013 and Consulting/Big 4 9% 2013 a erwards Operational Accounting 18% Risk 0% 12% Appointed Appointed in before 2013 2013 or later R604008-rr0063- CCO in FS v15.indd 6 14/04/2016 10:34:03 7 Asset Management CCOs: Compliance begins to come of age Historically, despite the close connection between Fully 71% have only worked in one or two functions. investment risk and operational risk in the asset Nowhere do we see the multifaceted “business side” management sector, investment-related risk has focus that is so common among banking CCOs – remained the responsibility of investment teams in asset management CCOs have traveled a clearly these businesses. CCOs (and their Chief Risk Officer circumscribed path to their roles. colleagues) have accordingly remained very closely That being said, we are witnessing an interesting trend aligned with Legal, and somewhat siloed as well as at a number of large to mid-sized asset managers, a result. We see this in the backgrounds of asset wherein the compliance function is being separated management CCOs: 68% have held compliance roles from Legal. We believe as this trend picks up in asset management, 41% have held legal roles in momentum, we will see CCOs in asset management asset management, 38% have worked for a regulator, whose backgrounds are more varied/more business- and 24% have worked for a law firm. focused. NUMBER OF DIFFERENT FUNctIONAL FUNctIONAL roLES HELD BY CURRENT roLES HELD BY CURRENT CCOs at GLOBAL CCOs at GLOBAL ASSET MANAGEMENT ASSET MANAGEMENT FIRMS DURING THEIR FIRMS DURING THEIR CAREERS CAREERS Compliance (Asset Management) 3 or more functions 68% throughout career 24% Legal (Asset Management) 41% Regulator 38% Legal (Law Firm) 1-2 functions 24% throughout career 76% Consulting/Big 4 Accounting 9% CHALLENGES SPECIFIC to BOUTIQUE ASSET Audit MANAGERS: 6% ɳ Small internal pipeline - 60% of CCOs at boutique asset management firms and 44% of Compliance (Commercial Banking) CCOs at global asset management firms were 6% externally appointed. Compliance (Investment Banking) ɳ Escalating compensation demands – some fund 6% managers are offering CCOs the opportunity to join the partnership in order to lure them from Risk larger competitors. 6% R604008-rr0063- CCO in FS v15.indd 7 14/04/2016 10:34:03 8 Insurance CCOs: still early days The compliance function in insurance companies is Insurers with a standalone compliance function tend still in its infancy. Indeed, less than half of insurance to appoint safe-choice candidates to the CCO role.