Regulators are right to focus on culture as a key culprit in the misbehavior of banks (“As Regulators Focus on Culture, Wall Street Struggles to Define It,” page one, Feb. 2), and efforts to survey and quantify corporate culture are important. But the reason culture is hard to define isn’t simply that it is a nebulous concept that is hard to capture objectively. The culture of an organization is analogous to the personality of an individual, in that it is defined by a set of normative, recognizable behaviors and traits that are durable and that characterize both what it is like to “live” inside that organization as an employee, as well as what it is like to interact with it from the outside, as customers, vendors, partners and shareholders.
Where the analogy to personality doesn’t hold is that organizations are greater than the sum of their parts. Unlike an individual’s personality, which is largely formed by young adulthood and resides solely in the mind of the person, the culture of a company emanates primarily from the personality of the founder or chief executive, but over time becomes embedded in other key individuals, and in practices and policies of the business. Nevertheless, the CEO wields the greatest leverage to create, sustain and change the culture. This can be a force for good or bad, as employees inevitably model the behavior they see at the top. The more regulators understand this, the less they will struggle to define culture and the more they will know where to look to address it when a company goes astray.