Oireachtas Joint and Select Committees

Wednesday, 29 April 2015

Committee of Inquiry into the Banking Crisis

Nexus Phase

Mr. David Duffy:

I'm not entirely familiar with the detail of those limits. It depends on whether ... I'll make it very black and white, Deputy: if there are limits that are around the sustainable nature of the bank's existence, those are limits that you have to define as a banker, not somebody else. Limits in the past I have seen, have been either indicative, guidelines, or tacitly accepted as too low, many different practices in different countries. But, again, I regard that as interesting but not the criteria that you manage a bank by. You yourself have to look to the sustainability of the bank under your fiduciary responsibility and in so doing you have to set the minimum capital and other thresholds that you have, and included in those are concentration risks. The model which we have in the governance of AIB now is very explicit. You are going to set limits, with the board's full involvement, to understand in all areas what your limits are at a maximum, whether by sector or individual. Any breaches of those have to be escalated to the board risk committee, which is chaired by a non-executive, not the executive. They are raised by the chief risk officer who, in our climate now, does not report to me but reports independently to the chair of the risk committee, who is a board member. So I think you have to say: is the right answer whether you can or can't breach? No. The right answer is: what is the right concentration? And you should not breach that if you think it's the right concentration. You set those limits based on your minimum capital and funding thresholds. That's the way I would work.

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