Our “fit and proper” standard covers not only competence, education and experience but makes specific reference to integrity, probity, as well as physical and mental fitness. In addition, we have mandated the creation of Board-level committees that will oversee Risk, Audit and Governance. We have also institutionalized a compliance system that should have the authority and independence to address the bank’s business risks.
These are check-and-balance type structures which are integral to a bank’s governance, alongside its own culture on the management of articulated risks. Equally important, disclosure and transparency requirements continue to be enhanced. Among others, disclosure requirements cover potential conflicts of interest, Basel 3-eligible capital instruments with loss-absorbency features and cross-selling.