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![](/i/favi32.png) Ifac papersOnLine 52-25 (2019) 148-153 ScienceDirect1-“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
“imaginative”
(Klaus Regling
and Max Watson - Report) in exploring macro financial
vulnerabilities and their linkages.
Respondents described a cultural malaise in banking
supervision which led to self-regulation
this
resulted in
evaluation metrics available being used too late or not at all
during the crisis
.
The evaluation metrics didn’t support the
establishment of a culture in banking of efficient and effective
communication and leadership
.
3.4 Social World
Systems technical failure and risk can be exacerbated by
human factors (Organ and Stapleton, 2013;2012; Lacey,
2009). The Fukushima Dauchi Nuclear Plant disaster is shown
as an example of how a dangerous failure is shaped and
consequences magnified by a multitude of human failures. It
showed how risk is produced by the coupling of different
human system elements. The failure to engage with risk from
a socio-technical perspective is a threat to local and global
socio-economic stability (Organ and Stapleton, 2018). The
tendency has been to look at risk from a functionalist
orthodoxy. Many of the most prominent technical
developments happened because of the creativity and
ingenuity of system developers (Kutsch et al., 2013; Ciborra,
2007).
Respondents highlighted the regulatory view of the social
world in relation to risk. Whilst acknowledging the structures
in place to deal with risk it didn’t
deepen the understanding of
the board or the management of risk from the banks growth, as
this testimony articulates
“A key issue in my view, is that
despite these structures, we the board and management did not
fully appreciate nor factor in the risk inherent in the rate of
growth of the bank's core businesses”
(Richard Burrows -
Statement). The understanding of what was risky or even
constituted risk, was confused and inappropriate. Risk was
constituted in a way that was inappropriate, which resulted in
the assumptions upon which conceptualisations were based
being flawed due to their attempt to find cause and effect
solutions to complex risk factors. The following testimony
when placed together shows these contradictions.
"No. I don't
believe there was an over-concentration. I think it was the
absolute amount given the subsequent collapse in prices"
(Brian Goggin
–
Testimony)
and
“
was left... heavily exposed
to the significant correction in the Irish and UK property
markets and was one of the major contributors to its requiring
State support
”
(Richard Burrows
–
Statement).
3.5 Additional Evidence
Whilst the findings in Organ and Stapleton (2018) is accounted
for in the theoretical framework in figure 1., there was a
category of findings which did not fit within the theoretical
framework synthesised in figure 1. Using NVivo the findings
of this study were clustered together for theorising purposes
see figure 2 below. The evidence was shaped under a simple
category
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