CBI Emphasizes Outcomes in Integrated Supervision

In a recent essay for the LSE Systemic Risk Centre’s Forum on Financial Supervision, Colm Kincaid, Deputy Governor for Consumer & Investor Protection at the Central Bank of Ireland (CBI), argues that integrated supervision can produce better outcomes by treating consumer protection, financial resilience, governance, and financial crime as interconnected rather than separate supervisory concerns.

Since January 2025, the Central Bank has brought conduct, prudential, and financial crime perspectives together within sectoral directorates covering banking and payments, insurance, and capital markets and funds. Kincaid says a firm’s financial resilience and its treatment of customers are “interconnected.” Operational failures can prevent customers from accessing their money, while poor sales practices can lead to costly remediation and reveal weaknesses in governance, risk management, or a firm’s business model. Integrated supervision is intended to identify these problems earlier and assess their wider implications.

The modernized Consumer Protection Code, effective March 24, 2026, reinforces firms’ responsibility to secure customers’ interests across product design, sales incentives, communications, and customer support. Kincaid argues that supervisors must assess how these obligations shape business decisions in practice, including whether boards and senior management have the information needed to identify and address customer harm.

A July 2026 review of complaints handling across insurance, intermediaries, payment institutions, and e-money firms also highlights the need to identify underlying problems rather than simply resolve individual cases. Kincaid notes that complaints data requires supervisory judgment: low volumes may reflect good service or difficulty accessing complaints processes, while rising volumes may indicate deteriorating service or better identification of problems.

Kincaid also used frauds and scams to illustrate the limits of supervision confined to individual firms. Fraud can involve regulated firms, online platforms, telecommunications providers, and cross-border actors, requiring coordination beyond the regulatory perimeter while preserving clear responsibility for each organization’s own controls. He argued that supervisors should assess both prevention and the treatment of victims, noting that sophisticated fraud controls can still produce poor outcomes if customers cannot quickly reach someone able to act.

“An integrated structure creates the opportunity for better supervision,” Kincaid concludes. “Demonstrating that it produces better outcomes is the continuing task … Success should be visible in consumers’ everyday dealings with financial firms, particularly when something goes wrong. That is where the benefits of integrated supervision must be felt.”