Deloitte noted a number of a general issues that potentially limit the effectiveness of the regime:  7 / 11  BIS central bankers' speeches  A reliance on high-quality directors to make the regime work.
The number of directorships held by directors, length of tenure, lack of banking experience, risk of capture by management and lack of diverse skills on the Board all potentially affect the effectiveness of the regime. There is a correlation between the effectiveness of the attestation regime and an open and honest culture within the bank.