As the Deputy will be aware since 2008 the banks in question have been subject to the 2011 PCAR and the recently completed Balance Sheet Assessment. Both of these exercises were conducted by the CBI and outside consultants and included a data integrity verification analysis that would have looked at the quality of the loan file data and documentation including security. Separately the banks are also subject to periodic file reviews by the Central Bank of Ireland and by their auditors as part of the statutory audit process.
It should also be noted that details in relation to the banks’ Risk Management Frameworks and governance are outlined in their respective Annual Financial Reports. The banks are required to review their lending policies and practices on an on-going basis and have made material changes to them since 2008. This includes a comprehensive and coherent suite of frameworks, polices, procedures and standards covering business and financial planning, corporate governance and risk management. The banks have a Group Risk Appetite Statement and a suite of Credit Policies which are reviewed annually and are subject to robust governance.
Finally I would point out that as part of the EU restructuring plan process, all three banks had to submit an analysis of what led to each bank’s difficulties in recent years, together with an explanation of what has been done to rectify these errors so as to ensure that they do not recur again in the future.