But as in the past, we should also be concerned about creating a level playing field. For that reason, the Board of Governors is continuing to negotiate with FINRA for it to act as our agent in collecting similar data from banks.
The sub-committees should report regularly and formally to the board which should stand ready to challenge any key issues as the board bears the ultimate responsibility. Corporate governance principles also require the bottom-up flow of information to the board through independent control functions such as the internal audit, compliance and risk management functions.