Earlier this month, the Central Bank of Ireland (CBI) launched a consultation on reforms to its Fitness and Probity (F&P) regime aimed at ensuring transparency, fairness, and efficiency.
The proposal follows an independent review conducted by Andrea Enria, former Chair of the Supervisory Board of the European Central Bank, which was published last July. In an appendix to the proposal, the CBI provided draft guidance that consolidates F&P standards, addressing conflicts of interest, collective board suitability, and the relevance of past events to applications.
Among the proposed reforms are revisions to supervisory expectations and updates to the list of pre-approval controlled functions (PCFs), roles which require CBI approval, reducing the total number of PCFs from 59 to 45 and removing sector-specific categorizations. The draft guidance outlines expectations around qualifications, experience, independence, and time commitments for PCF roles.
Alongside the consultation, the CBI published a report describing its progress in implementing Enria's recommendations. Therein, the central bank explains that it has established a new F&P Unit to oversee applications, ensure consistency, and refer potential refusals to a separate Gatekeeping Decisions Committee. In addition, a new process manual details interview procedures and commits to a 90-day timeline. Enhanced training and stakeholder engagement support the updated framework.
The consultation on the F&P reforms will remain open for feedback until July 10, 2025.
In an article published late last year, Edward Brooks, Executive Director of the Oxford Character Project at the University of Oxford, and Stephen Scott, Starling's Founder & CEO, argued that many regulators' approaches to fitness and propriety assessments underappreciate the impact of cultural context on individual character.
"Character manifests in social contexts beset by pressures, incentives and expectations that serve either to support or to subvert the cultivation and expression of virtue," they write. "In leaders, therefore, ‘good’ character virtues — ‘personal excellences’ — are those which enable them to discern, direct, and maintain a desired culture, often thought of as a kind of ‘corporate character.'" ▸ Read More
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