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As highlighted in the survey on the implementation of internal governance by institutions conducted in 2009 by the Committee of European Banking Supervisors (CEBS), weak governance practices coupled with excessive risk taking in the banking industry can be seen as one indirect factor that contributed to the current financial crisis. On the other hand, the banking supervisory framework in place has shown its failure to capture such practices and its consequences on the reliability of the banking system. In order to ‘fix the system’, the European Banking Authority (EBA)(1) published in September 2011 its Guidelines on Internal Governance (GL44). These guidelines, to be implemented soon in Luxembourg through a CSSF circular, cover subject matters like corporate structure, risk management...
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