Mr. Matthew Elderfield:

When the fitness and probity framework came in, effectively everyone was grandfathered under the law. That was the way it worked. Any new applicants must apply to us in what we call an individual questionnaire. This gives a lot of information to help us assess both the fitness and the probity sides of the equation. This comes into a central team and we look through that and make a judgment. For the higher impact firms, including the banks, we tend to do interviews for these roles and assess the fitness and probity. We have put in place a flagging system whereby if someone from one of the banks that required a Government bailout tries to come back into the system, a flag is raised. We then slow down the process and state we will be obliged to carry out an assessment of the individual in question and to ascertain what was the history of the position. For example, were they in human resources and therefore had no responsibility or were they in charge of commercial lending and, therefore, have some questions to answer?