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Ifac papersOnLine 52-25 (2019) 148-153 ScienceDirect1-“unwise”
(David Dilger - Statement)
.
In fact, testimony presented indicated that logically rational
functions used as a measure to control risk in banking
,
may
have in fact contributed to systemic failure in Irish banking.
Instead of linking remuneration and rewards systems in the
banks to profitability and risky behaviour those systems
incentivised contrary behaviours which led to breaches of
prudence and risk management embodied in governance and
risk management systems in banking. The following testimony
presented articulates this view
“a problem in the
procedure of
bank governance was the lending guidelines and processes
seem to have been widely short-
circuited”
(Klaus Regling and
Max Watson - Report) the testimony goes on to state
“the
failings of corporate governance seem to have been much
more a problem of deficient implementation that defective
guidelines and processes. With strong roles of boards, credit
committees, audit committees and external auditors, common
sense suggests that any systematic problems of this kind in an
institution should have be
en picked up”
(Klaus Regling and
Max Watson - Report)
.
3.3 Evaluation Metrics
Risk proved to be a complex issue and the causal factors were
dynamic. It is acknowledged that financial sector regulations
such as Basel II and the Sarbanes-Oxley Act requires risk
management evaluation and mitigation metrics that satisfy
observable processes and documentation (Jones and
Ashenden, 2005). Factors such as size of a business and
industry have influenced risk
,
however that causation hasn’t
changed the way risk is framed, studied or managed (Ciborra,
2007;2002).
Risk introduces significant constrictions on the functionality
of systems which hasn’t been acknowledged
by risk evaluation
metrics. Risk, unlike other non-
functional requirements hasn’t
been integrated into system development methodologies. Risk
evaluation metrics haven’t been exposed to necessary scrutiny
to determine their effectiveness. They lack the rigorous
scientific evidence underpinning there use as risk evaluation
metrics. This in turn affected the engagement by some with
risk management in systems development.
Evidence in the inquiry highlights external factors which
impinged as risk factors, but which were not quantifiable. For
example, light touch regulation which contributed to the crisis
was
“a cultural issue”
(Klaus Regling-Transcript)
,
suggesting
that cultural metrics which were not incorporated into risk
reporting were contributors. Not everyone agreed that some
banks were conservative (e.g. Bank of Ireland) and this was
described by some as a bank which
“did not have a cultural
problem”
(Denis Donovan - Statement)
.
It should be noted
that Bank of Ireland did not experience as much damage as the
other banks. Statistical tools used by banks and the IMF were
not sophisticated enough to capture the fiscal deficit in the
wider economy. The use of esoteric quantitative methods made
it difficult to classify some financial products. Respondents
believed stress testing of the banking system was too mild and
the tests failed to capture some risks that could not be
demonstrated functionally. For example, they failed to
combine funding and asset market factors and as a result were
not reliable when the context of market factors changed. They
were described as insufficiently
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