[DugFin]

Indeed, Martha Stewart is a prime example of how NOT to deal with the SEC. Turns out she wasn't guilty of insider trading, but she still went to jail for lying to the SEC about the trades in the first place. They take that very seriously.

[stickfigure]

This particular example seems to reinforce the argument for saying nothing at all.

[simonh]

Directors of companies have legal responsibilities to provide these reports to the government. So instead of the company getting a fine for making a mistake even though you tried to comply, now you are personally choosing not to fulfil your legal obligations as a director. Smart move.

[mattlutze]

The corporate veil is pretty tough, but that's one good way to give the government reason to pierce it.

[Bromskloss]

> Directors of companies have legal responsibilities to provide these reports to the government.

What if you don't tell the directors, but just fix the problem you have discovered? Is everyone off the hook then, or does that also amount to breaking the law (in some country)?

[zhte415]

Why you're in Operations or Technology in large financial companies, you're confronted with 'could do better' issues all of the time. All of the time. The more issues the greater the legacy of the system you're working on, as in this case, functionality has been altered from the original vanilla system (here, alphanumeric field type replacing a numerical feed type, the the documentation not being updated/references/or probably in an unreferenced document documenting the original system).

Spotting these things is a _fantastic_ way for a VP to get on the fast-track to Director. And it is fantastic, as a Director, to have people on your team actively looking for holes.

Why?

Because Operational Control is a #1 strategic target for all banks. $7million is nothing. At an extremely senior level this is evidence that a culture of transparency and compliance exists in the company, and ammo the next time the SEC or FED express a 'concern'. At a low level it is a Director or VP demonstrating to their boss that they understand the strategic direction, and that under their watch nothing big is going to blow up, nothing $7billion big; something $7million big is nothing, they know their boss knows this and will get a thank you for it being raised.

So you tell the directors. You make a nice PPT and include it in 'initiatives' when a senior visitor comes to visit and gets a de-brief on your department. You make sure it's carefully and clearly explained, so they can explain it to their boss in a nice, pro-active, continuous improvement kind of manner.

A bank which does not operate like this, in the post 2008 era of regulatory punishment for purgery, is an organisation with a very short future.

Source: Work in Operations and Technology in large banks.

[Apofis]

> nothing $7billion big; something $7million big is nothing, they know their boss knows this and will get a thank you for it being raised.

Further, this was obviously discussed with the boss before it was raised.

[Confusion]

And run the risk of losing big, instead of knowing for sure you'll lose small. Can you get a good estimation of the risk? If not, can you (not your company: you) afford the big loss?