Oireachtas Joint and Select Committees

Wednesday, 29 April 2015

Committee of Inquiry into the Banking Crisis

Nexus Phase

Mr. David Duffy:

I do believe we have. I mean it is important to define what I mean by that, Deputy, the important differentiation, for me, is the chief executive or the executive cannot be the arbiter of your risk accumulation. They can contribute, and the board contributes to a strategy, but when you are operating the bank, the people who originate must be separately accounted for in terms of those who approve. So independence of the risk function is fundamental. On top of that, the chief risk officer should not be reporting to the chief executive. If you were, as in some banks in the world today, or as accepted, you were the chief executive and you have a chief risk officer and you are paying his bonus or variable compensation, then you cannot say with absolute confidence that there would not be a conflict of interest at some point. So I think, one of the first things we did was, for both audit and risk, made sure the independence of reporting directly to a board member, non-executive, who chairs the risk committee is a fundamental principle of how you should operate. So that, and then our ... all of our policies, all of our guidelines which I have tried to document in my statement, with limits, with exception reporting explicitly mandated and required to be reviewed at the board, with all of those elements I believe we have the appropriate governance to prevent a re-occurrence.

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