October 4, 2010
The position of organizational ombudsman (ombuds) provides the quickest means to provide a structured layer of needed oversight in the financial community.
By requiring regulated agencies to universally deploy organizational ombuds programs, the SEC could create a needed level of oversight without creating additional bureaucratic red tape. The Ombuds Office provides for an effective way to ensure the discovery of unethical or non-compliant behavior and the resultant correction thereof. Usually people WANT TO DO THE RIGHT THING. They just do not have a way to do it safely. The Organizational Ombuds position provides them with that avenue.
The IOA (International Ombudsman Association) has already developed a Code of Ethics, Standards of Practice, and Best Practices for the position of Organizational Ombuds. Recently they have also established a certification process. The work done by the IOA, based on the principles of confidentiality, neutrality, independence, and informality, could easily be leveraged to support the goals of the SEC.
I encourage you to investigate the option of requiring regulated companies to provide Organizational Ombuds. Even the smallest company could provide this service from a qualified consulting companies. But, whether provided internally or by consultant -- our economy will not be secure until there is a way that individuals can safely and confidentially report breaches in compliance and/or non-ethical activities.
Good luck in your work.