Something that is sadly missing from the Patrick Neary involvement with Anglo is how the rules set up by a Regulator often apply to everybody bar them.

For instance, authorised firms are required to keep records for six years after the date of the transaction, the Central Bank not only didn’t keep records of the Anglo deal, they never made them to begin with it seems.

Here is a page of the various ‘codes’, you’ll note that none pertain the Central Bank, they don’t have any prescribed time frames to make responses, no service level agreement, no charter upon which to be externally judged. They have many pages on what everybody else must do, just none about themselves.

Chapter 11 of the Consumer Protection Code is solely dedicated to ‘keeping records’. It is safe to say that to an extent the financial services industry is the client of the Central Bank so why do they not keep records in the same manner as they firms they regulate must?

Failure results in sanctions (that means ‘fines’ to you and me’). Is this hypocritical? Can an institution realistically expect compliance to codes it wouldn’t adhere to itself? It does expect this, and has the authority to demand it, is that leading by example or best practice? You can decide that for yourself.