The review of the information flow extends from top to bottom, and with the expectation that bank senior management and boards of directors are actively involved in monitoring the bank’s activities and providing sufficient guidance regarding risk assumption. 1 “Independent commercial banking organizations” is defined as the sum of all bank  holding companies and independent banks.
Multi-bank holding companies are, therefore, considered as a single organization. BIS Review 93/1997  -4-  As in the past, performance of substantive checks on the reliability of a bank’s controls remains today a cornerstone of the examination process, albeit in a more automated and advanced form.