Federal Reserve rules require every large bank holding company to appoint one chief risk officer. The rule was approved on February 18, 2014, under the Dodd-Frank Act. Today it applies to companies with $100 billion or more in assets.
The officer has two bosses. “The chief risk officer must report directly to both the risk committee and chief executive officer of the company.”
On April 19, 1993, the FBI moved against the Branch Davidian compound near Waco, Texas. The compound burned, and 76 people inside died, 25 of them children. Attorney General Janet Reno had approved the operation.
That night she went on television. On Nightline she said: “This was a judgment I made.” And: “I think the responsibility lies with me.” On Larry King Live she said: “It is my decision. The buck stops with me. I am responsible for it.” Newsweek wrote that her candor gave her “instant cachet.”
New York State requires every cardiac surgeon to report the results of bypass operations. In late 1991, after a lawsuit by the newspaper Newsday under the state’s Freedom of Information Law, the state released death rates for individual surgeons by name, adjusted for how sick the patients were.
Surgeons responded. In a survey published in 1999, a majority of the New York heart surgeons surveyed said they had refused to operate on at least one high-risk patient. Accounts of the survey give the share as 62% or 67%. In a survey published in 2005, 79% of interventional cardiologists in New York said the report cards influenced whether they offered angioplasty to high-risk patients.
In 1975 the Supreme Court upheld the criminal conviction of John Park, the chief executive of Acme Markets. Acme was a national food chain with about 36,000 employees and 874 stores. Food in one of its warehouses in Baltimore had been “held in a building accessible to rodents.” Park was fined $50 on each count.
The Court, quoting an earlier decision, said that the food law “dispenses with the conventional requirement for criminal conduct—awareness of some wrongdoing.” It was enough that Park “had a responsible relation to the situation” and the power to prevent or correct it. Lawyers call this the Park doctrine.
In 2016 a federal appeals court upheld three-month prison sentences for Jack and Peter DeCoster, the owner and the chief operating officer of an egg company. In 2010 about 56,000 Americans had fallen ill with salmonella from contaminated eggs. The two had pleaded guilty to misdemeanors under the food law. Their liability rested on the Park doctrine.
On October 26, 2022, the Securities and Exchange Commission adopted Rule 10D-1. It carries out Section 954 of the Dodd-Frank Act. Every listed company must have a policy to take back incentive pay, such as cash bonuses and stock awards tied to financial results, from its executive officers when it has to restate its financial results.
The rule reaches back three years and covers former executives as well as current ones. Fault does not matter. Recovery “is required regardless of whether the executive officer engaged in any misconduct.”
An audit of an American public company is signed by the audit firm. Since 2017, the public can also learn the name of the one partner who led it. The Public Company Accounting Oversight Board adopted the rule in December 2015. For audit reports issued on or after January 31, 2017, the firm must file a Form AP that gives “the name of the engagement partner.”
The board said the rule was “intended to provide increased transparency and accountability for key participants in issuer audits.”
Truman kept a sign on his desk in the Oval Office reading exactly that, and used the phrase repeatedly to describe the presidency. The buck is passed, in American usage, from one person to another. The sign announces where the passing ends — at a named individual, in a specific room.
Directly Responsible Individual. Apple’s internal practice attaches a single name to every item on a meeting agenda, and the name is visible to everyone. American project management more broadly insists on one accountable person per item, and the phrase single throat to choke is used without embarrassment.
Product owner. Process owner. Account owner. Risk owner. Problem owner. American organizations name roles after possession of the thing rather than responsibility for a function, and the word carries the expectation that the owner acts without being asked.
That’s Mike’s project. She owns the redesign. He built that. Her numbers. American workplace speech attaches work to a named person as a matter of routine, in praise and in criticism alike. The attribution is automatic, and it runs both ways.