These are some suggested questions for students reading Stop Harming Customers: A Compliance Manifesto. The questions are useful for essays or discussions and are organized by chapter. Feel free to pick and choose the most appropriate for your class or to modify however you like.
Chapter: Introduction: ⅓ of a Trillion Dollars
Before reading the chapter
What do you know about economic crisis of the past? How often do they occur?
What do you know about banking regulation? Have you ever heard of a banking scandal or a bank being fined for misconduct?
Do some internet searching, can you find a finance or banking scandal or litigation happening right now? (I bet you can because they are always happening.)
After reading the chapter
Do you think ⅓ of a trillion dollars is a lot? Not so much? What are some things that cost a comparable amount of money? For example, how does that relate to military or health care or the GDP of countries?
Why do you think banks have been fined so much money?
Chapter: A July to Remember
Before reading the chapter
How many government regulators can you name without using the internet? How many after a search?
What news have you seen recently about banks or finance?
Do you think banking regulation is “boring” or “complex” or what word would you choose? Why do you think people may have a negative perception of bank regulation?
After reading the chapter
Do you think there are too many or too few regulators and regulations? What would you change about the system?
What do you think about the actions regulators took in July 2022? Were the penalties severe? Not severe? What would you change?
Do some research on the CFPB. What is its history? Why do you think some people like it and some people don’t like it? What is your view?
Chapter: What is Compliance?
Before reading the chapter
What do you think a bank Compliance department does?
If you were asked, “how do you make sure you comply with the law in your daily life,” what would you say?
What are some laws you have to comply with? How do you know about these laws?
What are some financial products and services you use every day? How many other financial products and services can you think of?
After reading the chapter
Do you agree that all financial products and services are a form of loans? Why or why not?
Do you agree that the law is always open to interpretation? Can you find examples of how legal interpretation has changed over time even if a law hasn’t been updated in a long time?
Research some “guidance” from a regulator. What does it say about interpreting the associated regulations? Do you think guidance has the same enforceability as the law? See if you can find a legal case arguing about this.
Chapter: How to Design a Compliance Department
Before reading the chapter
Can you think of any policies or procedures that apply to you? How important are they? How often do you read them? Why do you think people do or don’t read them?
Can you think of examples of things in your daily life that are “controlled”? (Here’s an example, a vending machine controls the disbursement of snacks.) How are they controlled? (The vending machine has locks and a plate of glass to stop free access.) How effective are the controls?
Do some research on “fractional reserve banking” and “capital reserve requirements.” What is the key idea of these concepts? What are the pros and cons of smaller versus larger capital reserves?
After reading the chapter
Can you think of any well designed but ineffective controls? How about effective but poorly designed?
Do you agree that controls, processes, and procedures are the same? If not, why not?
How effective is training? Can you think of examples of training that does not work? Why doesn’t it work?
Can you explain the risk assessment process after reading the chapter? What are the pros and cons of a risk assessment?
Do some research on a disaster in history such as the Chernobyl Nuclear Reactor, Challenger Space Shuttle, Bhopal Plant, BP Oil Spill, or any other. Could risk assessment have made a difference in the outcome?
Chapter: A Perfect World, Or Why Compliance Hasn’t Been Solved With Software
Before reading the chapter
Think about experiences you have had with “enterprise software,” meaning software designed for use in a professional environment and not by a customer. Examples might be department of motor vehicles, university registrar, job application systems. What are some differences between those systems and consumer-facing applications such as Amazon’s web store?
How many people do you think work in technology at a large bank versus at a software company such as Facebook, Google or Microsoft? What do you base this estimate on?
AI is continually improving. In between the time the book was drafted and now, ChatGPT has come on the scene. By the time you read this, technology will have advanced further. What do you think is changing because of technology and what isn’t changing?
After reading the chapter
Knowing that banks collectively employ hundreds of thousands of technology workers, do you think that’s a reasonable use of these resources? Why do you think it currently takes so many people to support technology at banks?
Similarly, what do you think about the number of people employed in Compliance departments? Is it too many? Too few? Is this the right way to think about “enough” compliance?
Do you agree or disagree with the book’s view on artificial intelligence? Have recent changes in technology changed your opinion? How much is your thinking based on what you have witnessed first hand versus what has been suggested as possible by marketing and news articles?
Chapter: Why Does Financial Crime Keep Happening?
Before reading the chapter
What are your thoughts on government regulation? Take an example from everyday life such as seat belts, vaccinations, immigration control, or anything else. What’s your view on the regulations and how the government does or doesn’t enforce them? Is this a net good for society?
What do you think the role of a financial regulator is? Should regulators be more about prevention or more about enforcement? In other words, should the regulators be seeking to protect investors from doing things that might lose money or should people be allowed to make bad investments? Is this really a dichotomy or are there other ways of how we should view financial risk and fraud?
What do you think about “financial innovation”? What comes to mind? Can you think of how this innovation has been helpful? How could it be used for fraud or crime?
Look into financial innovations of the past, such as credit cards and ATMs. What were some benefits? What were some negatives?
What do you think about cryptocurrency? Has your view changed over time?
After reading the chapter
Did you know what the three lines of defense were beforehand? Do you think the model makes sense or do you think it should be modified? How?
Has your view on financial innovation and cryptocurrency changed at all from before you read the chapter? How so?
What is your view on banking regulators after reading the chapter? Has your opinion changed? If so, how?
Chapter: A Compliance Manifesto
Before reading the chapter
Given what you’ve read in the book so far, (and well done getting here!), what do you think are some solutions for improving compliance?
How much do you attribute responsibility for compliance failures to individuals, corporations, and governments?
Do you think that the CEOs and other leaders of financial firms fundamentally want to do “the right thing”? What do you think “right” means to them?
If you (or someone you know) drive a car, what could be done to get you (or that person) to drive the speed limit? Under what circumstances would it work or not work?
After reading the chapter
What is your opinion of the manifesto theses? Are there any that you agree with? Disagree? Why?
Do you think there is more that could or should be done than what is proposed in the book?
Chapter: The End
What did you learn from the book that you didn’t know before? Is it useful information?
Will what you learned affect any financial decisions in your life? If so, what will you change?