Professor Philip Lane:

Let me emphasise that we have a parallel project in the bank to develop our own senior responsibilities frameworks. The Deputy will see on our website, when it is completed, phrases such as, "Here is what the governor is responsible for", "Here is what the deputy governor and the director general are responsible for", and so on. In mimicking that framework and being clear about who is responsible for what, we have had a big internal governance project in the past couple of years to reform all of our committees and to be super-clear about the accountability lines within the Central Bank. We hold ourselves to account regarding our performance as the regulator. That is perhaps slightly different from the way the Deputy phrased it. If we have failed, we will look at that. However, if there is a failure by the management of a bank, the bank is responsible. We cannot guarantee that every bank is going to conduct itself properly at all times. Our accountability relates to doing the best job we can as the regulator; it does not relate to taking responsibility where the banks should be responsible. I reiterate that we have this parallel internal project.

One interesting thing with the UK experience is that it reinforces the point that we waited. I am not disputing that maybe we should be quicker and all of that. However, when the Oireachtas moves to look at this, if it gets to it, it now has an evidence base and it is not just a hypothetical debate about whether this helps. The Oireachtas can perhaps take testimony from the UK about how this has been implemented in the past year or two. There were concerns in advance about whether this would scare people away and whether anyone would sign up to be the director of a bank, with this heavy responsibility on him or her. With regard to the facts of life about how it is operating, the Oireachtas will have hard facts from the UK to deal with. In general, I fully agree with the FCA. We are onto it in terms of saying, "Listen, if this is what we expect of the firms, we have to have something like that for ourselves."