Update On Bank Executive Accountability – October 2020

We have previously looked at the Central Bank of Ireland's (CBI) report on "Behaviours and Culture of the Irish Retail Banks" and the proposals for a Senior Executive Accountability Regime (SEAR). These proposals are currently with the Department of Finance where the legislation underpinning SEAR is being drafted and considered.

In the meantime, the ECB signalled in an opinion piece by Vice-Chair of the supervisory board of the ECB on 1 October 2020 that the ECB intends to implement "stricter and more intrusive" fit and proper assessments. The ECB intends to revise the existing Guide to Fit and Proper Assessment to ensure a more harmonised approach across the EU and will examine more closely the individual accountability of board members guilty of misconduct and those who turn a blind eye to misconduct by their peers. In addition there is to be increased scrutiny on reputation, such as previous criminal convictions or other ongoing proceedings and, of relevance to