Ms Derville Rowland:

Globally, conduct is to the forefront of regulation. Not just this jurisdiction but many others are looking at how we can further strengthen the regulatory frameworks. At the end of the day, responsibility for fair conduct rests with the providers of the service to the customers. What we have seen in Ireland and in other jurisdictions is that there is not much trust in the behaviour of the banks towards their customers. This is a global phenomenon. Accordingly, it is right that we further heighten the focus on the way products are sold to customers, such as looking in great detail at the behaviour that informs how they are sold.

A report on culture will be delivered in the middle of the year. Culture informs the motivations and results in the behaviours one sees. Does one have the right tone from the top of the organisations when one is designing and selling a product? Have the highest levels of the organisation decided what benefit this product will be to the customer and what is the right customer segment for it? Is it in fact being sold to the right customer segment? Are front-line staff being rewarded for delivering good customer outcomes? Are the right kinds of staff being promoted for this kind of behaviour and are they rising up the ranks?

In large organisations, one wants to see the whole of the system working in an integrated way from boardroom decisions right down to the provision of the service to the customers. We need to further strengthen our approach to ensure that it is structured and clear when we look at product governance and oversight, as well as closely examining the way which products are sold and if they are appropriate. We are committed to that.

We have also made recommendations to the Law Reform Commission about accountability and responsibility frameworks. It is likely that we will further develop those.