Goldman Sachs (NYSE: GS) released a 63-page report this week detailing how it plans to rebuild its image with clients and investors alike.
The heart of the report is 39 recommendations proposed by Goldman's new Business Standards Committee. In an ironic twist coming from a report promoting transparency, most of these recommendations were written in hieroglyphic legalese.
Here's a quick rundown of each one in English:
1. Re-emphasize client values.
2. Better communication with clients regarding employees' roles and responsibilities.
3. Increase emphasis on client services and relationships.
4. Strengthen client interactions.
5. Improve employee training on business principles and responsibilities.
6. Force department heads to communicate these changes to clients.
7. Require investment banking employees to seek management approval when engaging with trading department employees.
8. Move mortgage product underwriting from trading division to investment banking division. (There's better disclosure in investment banking).
9. Tougher rules to prevent traders and wealth planners from conflicts of interest immediately after investment banking transactions (such as IPOs).
10. Enhanced oversight when performing multiples roles for a single transaction.
11. Better oversight to prevent conflicts of interest in investment management, such as one department shorting a product another department is touting.
12. Better policies to prevent traders from inadvertently knowing about pending investment banking transactions.
13. Tell clients in plain, nonconfusing English what conflicts of interest Goldman might hold.
14. Improve employee training on potential conflicts of interest with clients.
15. Subject complicated structured transactions to strict managerial review and approval.
16. Subject large transactions to strict managerial review and approval.
17. Subject complex transactions -- those with leverage, illiquidity, nonlinear payoffs, etc. -- to strict managerial review and approval.
18. Restrict some nonprofessional clients from engaging in certain transactions without heightened approval. (Essentially preventing the sale of explosive material to widows and orphans).
19. Make a profile for each client with a list of products he or she is preapproved to transact in.
20. Follow up with clients after transactions to ensure products are being valued correctly.
21. Standardize disclosure between all departments originating securities.
22. Better overview of risk factors and scenario analysis on offering documents for new products.
23. Boost training for structured products across departments.
24. Three current business departments will split into four. From investment banking, trading/principal investments, and wealth management, the four new departments will be investment banking, institutional client, investing/lending, and investment management.
25. Include new balance sheet disclosure metrics for each department, including excess liquidity, secured client financing, market-making inventory, prop trading assets, intangible assets, and physical property.
26. Better disclosure of liquidity stress tests, including results of scenario analysis and modeling.
27. Disclose and describe in English the firm's risk management, business process, and culture (that last one should be good).
28. Rewrite entire business description in annual report to explain what the firm does.
29. Create a new committee to track reputational risk.
30. Create subcommittees for departments and regions.
31. Create another committee to follow new products.
32. Create yet another committee to quickly review big events, presumably such as being accused of fraud.
33. Enforce each committee's ownership to its duties; streamline committee reporting and framework.
34. Train senior leaders to reinforce the firm's culture.
35. Start a new forum on client and business standards led by the firm's chairman and CEO.
36. Emphasize reputational risk and judgment in annual performance reviews.
37. Design training procedures to adhere to each of these recommendations.
38. Emphasize leadership and values in the promotion process rather than just profits.
39. Update code of business conduct and ethics.
A few words about these changes.
One, it's great that Goldman recognizes its reputation is awful and in need of a fresh start. Admission of fault is always the first step.
Two, most of these changes are symbolic, trivial extensions of existing policies, and easy to avoid. The unshakable rule is that as long as "too big to fail banks" are allowed to exist under a lax regulatory environment, they'll be ethical swamps. That's just the nature of incentives.
Three, Goldman is, as far as I know, the only big bank to come out publically with a new rulebook. The others, JPMorgan Chase (NYSE: JPM), Citigroup (NYSE: C), Bank of America (NYSE: BAC), and Morgan Stanley (NYSE: MS), have not. And frankly they don't need to. Their reputation isn't nearly as bad as Goldman's.
But here's the thing. Goldman only has a terrible reputation because it engaged in Wall Street's dirty tricks and managed to make a fortune doing it. The others engaged in the same tricks, but they lost billions. We single out Goldman because its results were unique, but its ethical misadventures were pretty much par for the Wall Street course.
What do you think?
