Executive Summary Introduction

Systemic financial crises, like the recent Irish one, require a great number of institutions, enterprises and individuals to simultaneously follow unsound policies or practices. Each one is, of course, responsible for their own actions and inactions contributing to the accumulation and realisation of risks in financial markets. Nevertheless, responsibility for such a crisis is likely to be widely distributed. The Commission has, in keeping with its Terms of Reference, evaluated how various institutions contributed to the Irish financial crisis.

This Report explores what the Commission considers to be the most important policies, practices and linkages that contributed to the financial crisis in Ireland. A very large amount of documentation was analysed and many relevant people were interviewed. In explaining the simultaneity of the failures in Irish institutions, the Commission frequently found behaviour exhibiting bandwagon effects both between institutions ("herding") and within them ("groupthink"), reinforced by a widespread international belief in the efficiency of financial markets. Based on this, the Report finally offers some lessons that could help avoid future similar occurrences in Ireland and elsewhere. Much points to the development of a national speculative mania in Ireland during the Period, centred on the property market. As in most manias, those caught up in it could believe and have trust in extraordinary things, such as unlimited real wealth from selling property to each other on credit. Even obvious warning signs went unheeded in the belief that the world had changed and that a stable economy was somehow automatically guaranteed. Traditional values, analysis and rules could be gradually less observed by the banks1 and authorities2 because their relevance was seen as lost in the new and different world. When it all ended, suddenly and inexplicably, participants had difficulty accepting their appropriate share of the blame for something in which so may others were also involved and that seemed so reasonable at the time.

Preconditions for the Crisis

The international developments that facilitated the excesses in Ireland have been exhaustively documented in previous scoping reports. Entry into the euro area markedly reduced Irish interest rates. Banks had increased access to market funding, where cheap and abundant credit was already available owing to monetary policies in major countries as well as the increasing use of securitisation.3 Globalisation of markets and EU membership increased foreign competition in the Irish financial market, putting pressures on bank margins. A number of new, potentially high-risk retail products were introduced to the Irish market by new entrants (for example, tracker mortgages, 100% mortgages for first-time buyers). Last but not least, the paradigm of efficient financial markets provided the intellectual basis for the assumption that financial markets, left essentially to themselves, would tend to be both stable and efficient.

Footnotes:

1 Throughout this report the term ‘bank' will generally be used to refer to both banks and building societies and should be construed as such.

2 Throughout this report the term ‘authorities' will be used to refer to the Irish Financial Services Regulatory Authority (the Financial Regulator), the Central Bank of Ireland and the Department of Finance or to any one or combination of these.

3 The practice whereby banks sold off their loans to investors (often non-bank financial firms) by creating a security with these loans as collateral. The proceeds could then be used for providing additional loans that, in turn, could be securitised. Since banks but not the investors needed minimum capital, the same capital base could be used for substantially greater lending than before.

International developments, however, did not in themselves cause the crisis though they helped precipitate it. The problems causing the crisis as well as the scale of it were the result of domestic Irish decisions and actions, some of which were made more profitable or possible by international developments. Though eventually unsustainable financial risks were made attractive by outside factors, there simply was nobody abroad forcing Irish authorities, banks or investors to accept such risks. The way Irish households, investors, banks and public authorities voluntarily reacted to foreign and domestic developments was probably not very different to that in other countries now experiencing financial problems. However, the extent to which large parts of Irish society were willing to let the good times roll on until the very last minute (a feature of the financial mania) may have been exceptional.

Contagion

The willingness of banks to accept higher risks by providing more and shockingly larger loans primarily for commercial property deals was an important reason for the gradual increase in financial fragility in Ireland. This willingness occurred because of the emergence of strong foreign and domestic competitors within both the residential and commercial property lending markets. By mid-decade, Anglo Irish Bank (Anglo) and Irish Nationwide Building Society (INBS) were growing strongly on the basis of relationship banking, providing loans to a limited number of entrepreneurs operating in the riskier parts of the property market. Anglo in particular was widely admired domestically and abroad, and lauded (by many investors, consultants, analysts, rating agencies and the media) as a role model for other Irish banks to emulate.

This seems to have led to a gradual adoption of lower credit standards by a number of Irish banks (and it appears to the Commission that this was also the case for foreign-owned banks, as evidenced by reported losses) as a method to sustain market share and profitability. In some covered banks this strategy was consciously adopted by the board and was properly delimited. In other banks, boards seem to have simply decided on higher target growth rates, with little apparent realisation of the attendant risks; implementation (and risk policy) was implicitly left to staff.

Bank loans seem to have expanded so rapidly because neither banks nor borrowers apparently really understood the risks they were taking. Many banks were increasingly led and managed by people with less practical experience of credit and risk management than before. Property-related lending was seen as "really the only game in town" for growth-oriented banking. The purchase of second or more properties by individuals was seen as "a no-brainer". Rapid loan growth could not be funded by retail and corporate deposits; consequently, banks turned to the wholesale market.

The long upswing in the property market, accompanied by relentless media attention, eroded the risk awareness both of banks and their customers in Ireland. Banks, citing the long sequence of good years, generally saw little problem in expanding their lending by allowing credit quality and risk management to gradually erode. Likewise, households and investors had seen their incomes and wealth increase markedly for a number of years; easy access to credit further encouraged belief in a never-ending boom. In essence, both sides of the market assumed that the other side knew what it was doing. This helped ensure continued growth, profitability and funding in the market in the short term. However, this also meant that risk-related brakes on the growth of credit and leverage were weak and were growing weaker over time.

As banks increasingly funded the apparently profitable property market, a widespread and accelerating credit-financed boom in residential and commercial property developed from the first half of the decade. A self-reinforcing spiral developed: higher prices and values caused increased speculative buying of housing and land; evaluators based their estimates on these higher prices; this increased the demand and collateral for bank lending, which in turn raised prices as more funding was provided. This development ended as housing prices reached their peak at the end of 2006 and construction in early 2007. Furthermore, as bank funding dried up, the credit-driven property development sector started to experience liquidity problems. From then on, the link between property prices and funding accelerated the downturn and reduced banks' perceived creditworthiness, particularly as international accounting standards had prevented more prudent provisioning for possible future losses during the growth phase of the cycle.

Consensus

A majority of the people interviewed by the Commission indicated that they saw no major problems except lack of liquidity until the end of 2007, at the earliest, and autumn 2008, at the latest. The reasons given were usually very similar, the most prevalent being: property prices in Ireland had never decreased markedly; everybody expected a "soft landing" at worst; loan portfolios appeared sound; property credits were diversified by country or county or class; peer banks abroad did the same thing; and "nobody told them" there was a potential problem.

A minority of people indicated that contrarian views were both difficult to maintain during the long boom and unhealthy to present to boards or superiors. A number of people stated that had they implemented or consistently supported contrarian policies they may ultimately have lost their jobs, positions, or reputations. Other signs were also noted pointing to sanctioning of diverging or contrarian opinions as well as self-censorship because of this. The apparent strength of these expected sanctions is difficult to judge, but the absence of opposition, barring only a handful of identified vociferous contrarians, may have made it easier for institutions to accept toning down the application of vital, tried and traditional prudential practices.

The Commission suspects that this conformity of views and self-limitation of responsibility would have tended to reduce the perceived need for monitoring, checking and thinking about what was really going on. There would have been little appreciation - both domestically and abroad - of the fact that Irish economic growth and welfare increasingly depended on construction and property development for domestic customers, funded by a growing foreign debt.

The Commission considers that this pervasive pressure for consensus may explain why so many different parties in Ireland simultaneously were willing to adopt specific policies and accepted practices that later proved unsound. At the same time, the apparent consensus of banks and authorities around the view that markets remained sound and prospects remained positive gave further comfort to both. A number of banks essentially appear to have followed the example of peer banks in a "herding" fashion; there is little evidence of original critical analysis of the advantages and risks of the policies. Widespread lack of critical discussion within many banks and authorities indicates a tendency to "groupthink"; serious consideration of alternatives appears to be modest or absent. A tendency to favour silo organisation and submissiveness to superiors strengthened this effect, particularly among the public authorities.

In designing the constraints and rules for banking in the future, full account will need to be taken of the failure of private and public institutions to appreciate the emerging risks and to take action. If responsible authorities are affected by the prevailing paradigms, they cannot be expected to uncover its risks and weak points. Financial systems should, in that case, be designed to be as stable as possible even in the absence of unfailingly vigilant and prescient regulators and central banks. Flawed lending: Anglo and INBS

Anglo and to a much lesser extent INBS are important for the wider crisis because they were both seen as highly profitable institutions to which other Irish banks should aspire. As other banks tried to match the profitability of Anglo in particular, their behaviour gradually, and even at times unintentionally, became similar. Accordingly, when the crisis broke, large losses were realised not only in Anglo and INBS but in other banks as well.

Contrary to public perception at the time, lending at Anglo and INBS had proceeded with insufficient checks and balances during the Period. Relationship lending, high-growth strategies and rapid credit decisions meant that their balance sheets increased as the projects of preferred customers grew. Traditional risk evaluation procedures and risk mitigants were not implemented in practice. Additionally, these banks were very dependent on wholesale funding due to their rapid asset growth and a lack of sufficient growth in customer deposits. As wholesale funding tends to be much more volatile than customer deposits, they were particularly vulnerable to any doubts regarding their own solvency or that of their borrowers.

Governance at these banks also fell short of best practice. While procedures and processes in Anglo existed on paper, in certain cases they were not properly implemented or followed in practice. It appears that, at least in the latter years, only a handful of management was aware of all activities of the bank. At INBS, a number of essential, independent functions either did not effectively exist or were seriously under-resourced.

The Financial Regulator(FR) was clearly aware of many of these problems in the two banks. Prior to the commencement of the Period, and consistently throughout, it raised significant concerns regarding governance at INBS. It also submitted a comprehensive list of procedural and portfolio problems to Anglo. It furthermore raised minimum capital ratios for both banks. However, such remedies did not prove effective to ensure sufficiently greater prudence and accountability in either of the banks. The system-wide increase in capital charges on certain property loans in 2006, while appropriate in principle, proved too modest in a situation where property lending appeared hugely profitable. As a result, to outsiders, the two banks may have appeared to operate in ways broadly acceptable to the FR. This may have increased their importance as role models for other Irish banks. It must also have given comfort to leadership in the two banks themselves and encouraged them to continue with these practices.

The Herd: Other Banks

Bank management and boards in some of the other covered banks feared that, if they did not yield to the pressure to be as profitable as Anglo, in particular, they would face loss of long-standing customers, declining bank value, potential takeover and a loss of professional respect. The few that admitted to feeling any degree of concern at the change of strategy often added that consistent opposition would probably have meant formal or informal sanctioning.

Bank management and boards generally gave in to this pressure, in the bigger banks more so than in the smaller ones. Strategies chosen included concentration on retaining market share, increasing earnings growth and protecting the banks' franchise. The implementation of these strategies as well as comprehension of what they meant for the bank's risk profile varied between institutions. At their most prudent, limits were placed on credit volume to riskier markets and customers were selected based on prudential characteristics. At the other end of the scale, boards adopted general high-growth credit volume or profit targets without apparently really understanding how they would be implemented in practice by staff. It seems to have been quite generally accepted that - traditionally volatile - market funding would continue to be available to enable the achievement of growth targets. The relative level of prudence of the banks, on both the asset and liability side of the balance sheet, was eventually reflected in the extent of the losses suffered by each institution.

Unfortunately, in many cases the documentation of discussions among board members over the Period was, in the view of the Commission, insufficient. A number of members interviewed indicated a strong preference for consensus on boards as well as among managers. It appears to have been difficult for individual members, especially those without banking experience, to express and maintain a view contrary to the majority view on the board. In some cases, members indicated that their approach was to initially register their opposition to a particular decision, but to then adopt the majority view. Contentious issues or strategies were, probably also in the interest of efficiency, seldom revisited unless it was jointly agreed to do so. Over time, managers known for strict credit and risk management were replaced; there is no indication, however, that this was as a result of any policy to actively encourage risk-taking though it may have had that effect.

In addition, there were some indications that prudential concerns voiced within the operational part of certain banks may have been discouraged. Early warning signs generated lower down in the organisation may in some cases not have reached management or the board. If so, the pressure for conformity in the banks has proven to be quite expensive.

The Silent Observers: External Auditors

The auditors, like other professionals in the banks, had the skills, opportunity and procedures required for detecting and evaluating asset and funding risks. While not working full-time in banks, by long tradition auditors have full access to bank documentation and pronounce on the accuracy of the historic accounts on the basis that the bank will remain solvent a year forward. Within their specific remit auditors provide often voluminous reports to their clients.

Auditors have a number of ways to inform bank leadership of any concerns. In addition to the public audit opinion they give the Audit Committee a more detailed report on their findings on the business and provide a letter setting out any weaknesses identified in the bank's reporting systems. They are also required to provide the FR with copies of these reports. Auditors' commentary, however, regularly focuses only on issues which they consider relate to the accuracy of the historic accounts. In practice, this means that auditors look primarily backwards and at technical issues that may influence the accuracy of the accounts. Nevertheless, auditors are also required to assess whether a bank will remain a going concern for the next year; this seems to require them to make a judgment on at least the shortterm sustainability of the bank's business model and strategy.

The auditors clearly fulfilled this narrow function according to existing rules and regulations. They did not, however, generally report excesses over prudential sector lending limits to the FR. Even if they had, it appears unlikely that anything would have been done about it as in general the FR was already aware of such limit excesses.

A judgment on whether the bank is a going concern for the next year would appear to depend inter alia on the quality of governance in the bank. It might be reasonable to argue that a bank's governance and procedural problems may, over time, be reflected in the quality of its loan book or in the stability of its funding, particularly when inherent risks in these are growing rapidly. For banks, closure usually comes because liquidity dries up; only later may it turn out that the bank's assets also are impaired and have caused its creditworthiness to decline. It may be difficult to accurately judge exactly when this occurs. In fact, this is what happened in Ireland, where banks had to be rescued from closure by the Government Guarantee in some instances not more than six months after being given clean audit opinions.

The problems in the Irish banks were building for several years before the crisis. These were problems of credit quality, sustainable lending practices and adequacy of internal procedures; they were not generally operational problems related to the IT systems or the mechanics of loan documentation. Auditors, therefore, did not feel that commenting on the implications of such business model problems fell within their proper remit. In fact, it may be questioned whether they even saw them as problems since very few others appear to have seen them either. On these issues, they appear generally to have stayed silent.

The problem of clean audits followed by a threat of closure a short time later is not new nor is it limited to Ireland. As a result of the global financial crisis several initiatives are under way to explore ways of making audits conform to the "watchdog" expectations which are both in the market and among the public. It would be useful if the Irish authorities, building on their own experience, would take an active role in these deliberations.

The Enablers: Public Authorities

The Central Bank (CB) and the FR noted macroeconomic risks and risky bank behaviour but appear to have judged them insufficiently alarming to take major restraining policy measures. Among all the authorities a very limited number of individuals, either in boards or among staff, saw the risks as significant and actively argued for stronger measures; in all cases they failed to convince their colleagues or superiors. Thus the authorities largely continued to accept the credit concentration in the property market and avoided forcing action on the failings in the banks. The Government actively supported the market over an extended period against the apparently fairly weak but clear opposition of the Department of Finance (DoF).

The CB had a pivotal position, itself contributing to overall financial stability and being able to direct the FR. In the view of the Commission, macroeconomic developments were already exhibiting signs in 2005-2006 that reasonably should have caused concerns in the CB. However during the Period in question, it did not take forceful measures but largely confined itself to providing reminders of existing risks. This did little to alert banks or other authorities to the growing foreign debt or to potential stability risks from the property boom and the overheating economy. The need to avoid spooking the market appears to have been an increasingly common reason to do and say little; however, this cannot explain the lack of clear confidential warnings to other authorities. There may have been a state of denial in the CB; warnings of stability risks appear to have been sidestepped internally or, when made public especially in the Financial Stability Reports, toned down in the policy conclusions. Trust in a soft landing was consistent and, though not very well founded, continued up until and including the crisis management phase of the Period.

The CB was not powerless; it had the right to direct the activities of the FR and it could advise the Government. There are, however, no records of such direction or advice or even efforts at such. These institutions worked separately and their respective independence was repeatedly stressed; however, this was counteracted by their partly common board members. Until the crisis, many of the staff of the CB and the FR apparently did not cooperate in a sufficiently meaningful way in assessing financial stability. This, together with the determined optimism and caution of senior management, may help explain why so few staff were seriously concerned about stability issues at the time. It appears that each of the authorities ultimately assumed that the other conscientiously fulfilled its prudential tasks. Thus, less was done than either of them assumed.

The problems in Anglo and INBS in particular, were not hidden but were in plain sight of the FR and the CB. The funding strategy of Anglo was obvious from its balance sheet and the concentration to the more speculative part of the market was generally known. Similarly, INBS's expansion into development lending was also clearly documented and the governance problems in the bank were widely known by the authorities. While these issues were repeatedly addressed by the FR, only modest results were eventually achieved as their later losses indicate. While the poor state of loan documentation in INBS and insufficiency of collateral in both would have required closer inspection, such information was readily available to the FR. Had they considered it necessary or appropriate, there was sufficient information to have allowed the authorities to take more decisive action than was the case.

Surprisingly, since the FR saw itself as regularly meeting with the banks, interviewed bank management and board members could not recall any meaningful engagement with the FR on prudential issues (except technically, as part of the Basel II process).4 According to bank management, prudential issues were tick-the-box checks that formal procedures were in place, not checks on how they worked in practice. On the contrary, when prudential sector concentration ratios were exceeded, the FR did nothing to demand any limitation in risk exposure despite being fully informed. The FR's passiveness with regard to sanctioning, as a matter of urgency, the weaknesses in governance and risk management in Anglo and INBS has been set out above. Consumer issues were exhaustively, publicly and actively dealt with by the FR, however.

The DoF and the Minister for Finance were regularly provided with a Financial Stability Report, officially jointly written by the CB and the FR. In practice, the FR appears to have participated primarily at board level.5 The report occasionally made reference to the frothiness of the Irish property market but did not explicitly infer serious risks to the banks from this emerging bubble. The banking sector considered the overall tenor of the report to have been benign and comforting. Being conscious and supportive of the independence of both the CB and the FR, the DoF provided very little comment or input to this process,6 nor did it assess how they fulfilled their duties until very late in the Period. Neither the CB nor the DoF seem to have considered the implications of a possible interruption in the flow of foreign funding. If such a scenario had been considered, the link between such funding, property market developments and bank solvency could perhaps have been uncovered.

Generally, international organisations (IMF, EU, and OECD) were, at most, modestly critical and often complimentary regarding Irish developments and institutions. This gave the authorities and the banks additional reason to assume that all really was well. Domestic doubters were few, late and usually lowkey, possibly because it was thought that expressing contrarian views risked sanction; in addition, a long period of good times had reduced the numbers of those willing to continue to go against the prevailing and apparently proven consensus.

4 Given that the FR did send post-inspection letters to banks requiring serious action, this view is difficult to explain. In one late case, it appears that the letter was not distributed to the Board. In other cases, it may be that FR contacts were made by "too low-level" officials or that the issues were seen as technical rather than strategic in importance. Finally, it may be that issues that the senior FR officials considered substantive in a prudential sense were seen by bankers as formal or technical only.

5 This was explained to the Commission as the combined result of inter alia bad relations at times between leadership and staff in the two institutions, time constraints by regulatory staff, the lack of economics skills in the FR and difficulties in achieving mutual comprehension (the different professional languages of economists and accountants). To the Commission it seems that this lack of cooperation is stemmed largely from lack of leadership at various levels in both institutions. Cooperation problems may have been compounded by a solid lack of understanding of stability issues at most management levels.

6 The Secretary General would provide comments as a member of the Board of the CB. His membership could, for its part, possibly also reassure DoF staff that the CB and, to the extent that stability issues were raised by the FR at the CB Board, that also the FR was doing an adequate job.

Policy with Insufficient Information: the Guarantee The lack of suspicion and the absence of sufficient information on the underlying quality of the banks' balance sheets is likely to have had a significant impact on the alternatives that were considered reasonable on September 29, 2008. Proper information is a precondition for any crisis management based on reality. As it turned out, decisions were made on the erroneous assumption that all banks were and would remain solvent. Only on that assumption could the decision to simply provide a broad guarantee be understood.

Given the information available and the imminent liquidity problem at the time, the Commission understands the pressing need to ensure access to liquidity for the banks the next morning. The broad and legally binding guarantee did, however, represent a considerable risk to the sovereign in the case of any negative surprises. Moreover, there appears to have been some market perception that Irish banks were excessively exposed to the property market and the consequent risk of bad debts. It could, therefore, have been useful to consider using other available financing for a few days, using the time to assess ways of limiting the Guarantee and to urgently scrutinise the state of some banks. Given market sentiment at that time, however, the risk of further destabilising the situation would have been substantial. In any case, whilst alternative forms for the Guarantee were contemplated, they were not seriously considered since they, in the judgment of the authorities at the time, posed greater risks than benefits.

If accurate information on banks' exposures had been available at the time it seems quite likely to the Commission that a more limited guarantee combined with a state take-over of at least one bank might have been more seriously contemplated. Indeed, on the basis that such information had been available, banks could have been directed to raise substantially more private capital well before end-September 2008. As it turned out, however, the Government was advised that banks' insolvency risks were small relative to liquidity risks and it was eventually decided not to consider nationalisation. This proved to be only a temporary reprieve, however. After a series of insufficient government actions and initiatives, Anglo was nationalised on January 19, 2009 following the disclosure of significant governance failings. Shortly afterwards, the solvency implications of several banks' excessive property exposures started to emerge.

Some Lessons

Since the international financial crisis started, regulations have been tightened and institutional arrangements changed both in Ireland and in a number of other countries. A large number of groups, both national and international, have provided insightful analysis and recommendations on how to enhance the prospects for financial stability.

It is not the intention of the Commission to insert this Report into that wide arena. However, the Commission's work has highlighted some potential lessons from the banking crisis in Ireland that appear relevant from the point of view of reform; it seems only reasonable to offer them for potential wider consideration.

A main lesson is the need to make sure, both in private and public institutions, that there exist both fora and incentives for leadership and staff to openly discuss and challenge strategies and their implementation. It must become respectable and welcome to express professionally argued contrarian views; neither this crisis nor many others have been or will be foreseen by the consensus view of professionals or managers. One way might be to regularly assess "worst case" scenarios relating to proposed strategies and forecasts, with a strong emphasis on using historical and international experiences. Additionally, lower-level staff could be more frequently consulted on implementation issues and their implications.

To help promote an even greater awareness of risks, such analyses need to be shared with all relevant parties; while this should lead to remedial action it need not, however, necessarily require open public discourse. In part because they must form a view on banks' financial sustainability, bank auditors should have a regular, compulsory dialogue with its client's senior management and boards on the bank's business model, strategy and implementation risks. The result of such discussions should also, at least when clearly relevant, be communicated to the FR.

Furthermore, authorities as well as bank boards and management need to remain particularly vigilant and professionally suspicious during extended good times. Nevertheless, history indicates that this is unlikely to be the case, in practice, for a number of reasons. Thus, it seems unlikely that regulatory or governance reform alone will prevent a future crisis. This argues for structural changes in the banking sector, appropriately reducing and delimiting at least the part of the banking system that may be subject to the various types of government support. The economic size of the country and the sovereign as well as moral hazard considerations should affect the extent of such constraints. In addition, in order to slow a renewed "procedures creep", banks should consider establishing internal, hard voluntary lending limits which they would make difficult to change or circumvent.

Also, the selection of management and board members in both responsible authorities and banks may need even more attention than before. It is the impression of the Commission that long, preferably practical, experience in financial markets has a tendency to promote not only competence but also financial prudence. Banks might do well, in the long run, to ensure that their senior management has, or at least has close access to, extensive lending and risk management expertise; more banking experience in boards would also prove useful. Authorities might also do well to make even greater use of experienced practitioners, domestic and foreign, in various roles.

Additionally, cooperation between all relevant authorities needs to become less formal but more comprehensive and should include professional staff. While accountability requires clarity on who makes a decision, the need for good decisions would seem to require regular, open, professional and constructive discussion among all relevant institutions. In that regard, much remains to be done in Ireland and elsewhere. For instance, it seems particularly vital to urgently and substantially increase staff with financial market expertise in the DoF for it to be able to actively fulfil its part of the stability mandate, including cooperating closely and professionally with the CB and internationally. Finally, it appears to the Commission that little seems to argue against policies to markedly limit (even properly structured) bonus and pay for management in both banks and authorities, in Ireland and internationally. A consistent message of the bankers interviewed by the Commission has been that money is only part of their work incentive. For people serious about professional public service, money should be even less of an incentive.

ABBREVIATIONS:

AIB Allied Irish Bank
Anglo Anglo Irish Bank
ALCO Asset and Liability Committee
BoI Bank of Ireland
C&P Construction and Property (Sector)
CB Central Bank of Ireland
CBFSAI Central Bank & Financial Services Authority of Ireland
CEBS Committee of European Banking Supervisors
CFD Contract for Difference
CRO Chief Risk Officer
CSO Central Statistics Office

DOE Department of Environment , Heritage and Local Government
DSG Domestic Standing Group
EBS Educational Building Society
ECB European Central Bank
ELA Emergency Liquidity Assistance
ESRI Economic & Social Research Institute
EU European Union
FR Financial Regulator
FSA Financial Services Authority
FSAP Financial Sector Assessment Programme
FSR Financial Stability Report
GDP Gross Domestic Product
GNP Gross National Product
HBOS Halifax Bank of Scotland
IA Internal Audit
IAASA Irish Auditing and Accounting Supervisory Authority
IAS International Auditing Standards
ICAI Institute of Chartered Accountants Ireland
IFRS International Financial Reporting Standards
IFSC International Financial Services Centre
IL&P Irish Life and Permanent
IPD Investment Property Databank
IMF International Monetary Fund
INBS Irish Nationwide Building Society
IT Information Technology
LTC Loan-to-Collateral
LTV Loan-to-Value
MIS Management Information Systems
MTR Medium Term Review
NAMA National Asset Management Agency
NED Non-Executive Director
NPRF National Pensions Reserve Fund
NTMA National Treasury Management Agency
OECD Organisation for Economic Cooperation and Development
ONS Office of National Statistics (UK)
PwC PricewaterhouseCoopers
RBS Royal Bank of Scotland
QEC Quarterly Economic Commentary
SI Statutory Instrument