|See Chapter 5.|
Numerous questions tumble out of the cracks of the FSA's report on the destruction of Bank of Scotland: where is the review of the FSA's ARROW visits (as for Northern Wreck)? who were the key participants and their highly paid flunkies? Were any of them also responsible for the bank's £20m worth of bad attitude to complaints, by any chance?
For the tuppence it's worth, the report says that from 2006 to 2008:
"(1) there were serious deficiencies in the control framework, which meant that it failed to provide robust oversight and challenge to the business;
(2) there were serious deficiencies with the framework for the management of credit risk across the portfolio which meant that there was a lack of focus on the need to manage risk across the portfolio as a whole;
(3) there were serious deficiencies in the distribution framework which meant that it did not operate effectively to reduce the risk in the portfolio; and
(4) there were serious deficiencies in the process for the identification and management of transactions which showed signs of stress which meant that they were neither identified promptly nor managed effectively."
And there were:
"targets which incentivised ...:
(1) prioritising the development of relationships with and the facilitation of customers;
(2) increasing the appetite to lend;
(3) increasing the appetite to take on greater credit risk;
(4) fostering an attitude of optimism at the expense of prudence; and
(5) regarding risk management as a constraint on the business rather than integral to it."
Furthermore, there were:
"significant issues as to the quality, reliability and utility of the available management information which directly affected the effectiveness with which the risks of the business could be assessed, managed and mitigated."
"(1) Group Risk failed to conduct effective oversight and control of Corporate; and
(2) there were issues with the quality and scope of assurance work undertaken by Group Internal Audit."
The FSA's solution?
"In these exceptional circumstances, the most effective way in which to balance the need for deterrence and act in the wider public interest is to issue a public censure."