Regulatory capital in banking goes through more governance scrutiny in a single quarter than the commercial system generating the revenue that capital is meant to support receives in three years. I am not suggesting capital governance is excessive. I am observing that the asymmetry creates a specific and underexamined operational vulnerability.
The commercial system generating net interest income, fee income and digital product revenue is carrying structural risks that are not being examined with the rigour applied to the balance sheet. Concentration risk in customer acquisition channels. Dependency on performance marketing environments operated by platforms who change the rules unilaterally. Retention assumptions built on a competitive environment that has shifted. Attribution models producing confident numbers on assumptions nobody has revisited.
Those are commercial risks with financial consequences. They sit outside the governance framework that was built for financial risk because nobody built the framework that covers this category. That is a gap the CFO is best positioned to close.
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