Oireachtas Joint and Select Committees

Thursday, 23 April 2015

Committee of Inquiry into the Banking Crisis

Nexus Phase

Mr. Dermot Gleeson:

Regulatory limits are described ... there are 1995 standards is what they're known as, and they're described by the regulator in the following terms in the 1995 standards: "As many of the provisions are of a discretionary nature, the bank has set down requirements and standards which it uses to guide it in the supervision of the business carried out by credit institutions." So, it was used as guide in supervision. Now, let me say this to you: we would have been very well off not to have exceeded that sectoral limit. It's a great shame that we didn't. But if I can describe to you what was going on at the time, it was Basel II, and we were written to by the regulator in February 2007, shortly after that, and I'm going to read the first sentence ... the first two sentences. This is the regulator to our manager:

In the light of the requirements of the Capital Requirements Directive, and in particular Pillar 2 requirements on concentration risk, the Financial Regulator is currently reviewing its sectoral concentration framework. As part of this review I am contacting credit institutions that have experienced difficulties with the current sector limit.

We replied; I won't read out the reply because it's long and you've asked me to be short, but the reply did say, "We are now dealing with this under Basel." That reply was from Mr. Bhattacharya, the chief group risk officer, on 2 May, and there's two other pieces of information that I need to give you. In June of 2007 we put in our Basel II application to the regulator, a document that I'd say ran to 1,000 pages, with all sorts of mathematical formulae. The board, in June 2007, had to approve a sort of summary of it, and that summary included - and you have these papers - that summary included a section on credit concentration risk. The document is called the Basel Programme Governance Workstream. It had to be signed off and approved by the board, and that described the risk model that we were using for concentration risk, Moody's KMV portfolio manager, the one used by the Basel committee itself. And the conclusion, having applied that model to our concentration issue, was that based on the analysis conducted - I'm skipping a lot here - "AIB does not require additional capital requirement for credit concentration risk". We sent that application in and it was approved by the regulator.

Now, as I say, let me go back to basis. We'd have been much better off at the old limit.

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