4 Report approach and value
The need for transparency and
accountability
94. The financial crisis that began in 2007 had
a very serious impact on both the financial system and economy
of the United Kingdom. In order to maintain financial stability
the Government of the day took unprecedented action: it took ownership
of Northern Rock and of part of Bradford & Bingley, and bought
large stakes in Lloyds Banking Group and the Royal Bank of Scotland
(RBS). These interventions are still weighing on the Government's
finances. According to the National Audit Office:
The total outstanding support explicitly pledged
to the banks as at 31 March 2011 is £456.33 billion, down
from £612.58 billion as at 31 March 2010, and from a peak
of some £1.162 trillion. The total outstanding support is
31 per cent of Gross Domestic Product as at March 2011. Of the
total support, £123.93 billion was provided in the form of
loans or share purchases, which required a transfer of cash from
the Government to the banks. A further £332.40 billion relates
to guarantees and other forms of contingent liability where the
Government will only provide cash if certain events arise.[129]
95. The sheer scale of the Government intervention
as a result of the financial crisis underlines the necessity of
properly understanding the causes of the crisis, and the causes
of individual bank failures.
96. By far the largest recipient of capital from
the Government was RBS, who received a total of £45.8 billion
in cash injections during and after October 2008.[130]
97. In putting out a one-page,
298-word summary of their decision not to take enforcement action
against the bank or any individuals after their investigation
into RBS, the FSA showed an astonishing lack of appreciation of
the understandable public interest in the failure of RBS.
At the time, Lord Turner argued in an opinion piece in the Financial
Times that:
The causes of the crisis and the role of ill-designed
international regulations, poor supervisory practices and bank
risk-taking are well understood. In April 2008 the FSA published
a report into the Northern Rock failure and set out, more openly
than any other financial authority, the inadequacies of our approach.
A complete reform of FSA supervisory approaches followed. Then
in March 2009 we published my own Turner Review, which detailed
how globally agreed capital adequacy and liquidity rules were
woefully deficient pre-crisis, allowing banks to take dangerous
risks. The international community is midway through radical reforms
to put this right too.
It would be possible to add a report looking just
at the RBS story. Such a report would be more comprehensive than
the FSA's internal investigation, which focused solely on whether
individuals broke FSA rules. But it would add little, if anything,
to our understanding of what went wrong.[131]
98. The assessment of Sir David Walker was that
putting out a one-page statement was both "unreasonable"
and "a mistake".[132]
In a letter to the Chairman of this Committee on 11 December 2011
Lord Turner acknowledged the "legitimate public interest
in receiving a detailed account of this very major bank failure",[133]
and at the time of his appearance before the Treasury Committee
on 30 January 2012 he admitted that he had underestimated the
strength of public feeling in relation to the RBS failure:
I entirely accept that what we, and I personally,
failed to focus on at the time was that it is important when something
has gone wrong that there is a public account of it. We stuck
too narrowly to our existing procedures. [...] I wish that back
in 2009 Ior other people might have suggested ithad
realised that the failure of RBS was such a big thing that we
should have a public accountability report. That is what I now
believe.[134]
He also agreed with Sir David's assessment that the
FSA had made an error, saying that they were "not being imaginative
enough in realising that this would require a wider accountability.
That was a mistake."[135]
99. The public interest in the failure of RBS
in part reflects a desire simply to understand what went wrong.
Transparency is also necessary to ensure that Parliament is equipped
with the information it needs to ensure that the raft of financial
services regulation being proposed at the moment reflects the
lessons learnt from mistakes made in the run-up to the crisis.
Transparency is, moreover, crucial to our ability as a Committee
publicly to hold regulators to account. Hector Sants acknowledged
the necessity of this when he appeared before the Committee, stating,
"I also strongly believeand this report and this process
is part of itthat the regulators should be accountable
for what they have done and the actions they have taken."[136]
100. There is a clear need in
cases of bank failure of the magnitude of RBS for public accountability
about how and why that failure has occurred. Where publicthat
is ultimately taxpayers'money is used to support a business
in the private sector there is a need for a full public explanation.
In December 2010 the FSA initially felt that a 298-word statement
about RBS's failure was explanation enough. This reflects serious
flaws in the culture and governance of the regulator. It also
reflects a fundamental misunderstanding of its duty to account
for its actions to the public and Parliament. In view of the vast
amounts of public money committed to propping up RBS, Lord Turner's
comment that a Report into the demise of RBS "would add little,
if anything, to our understanding of what went wrong" was
inadequate. He should have grasped the need for a public explanation
of how that situation had arisen, something which he has subsequently
acknowledged. We would not expect the new chairmen of the regulators
to repeat the error.
The review process: efficiency,
value for money and objectivity
VALUE FOR MONEY AND EFFICIENCY
101. The FSA Report into the failure of RBS took
the form of an internal review (that is, the bulk of the review
was conducted by FSA staff), supplemented by the oversight and
observations of independent reviewers appointed by the Treasury
Committee. The Report therefore not only answers the need for
public accountability about the failure of RBS, but also acts
as a test-case for this approach.
102. Evidence we received on the approach focussed
on two main areas: efficiency and value for money, and objectivity.
In his evidence to us, Sir David highlighted one considerable
advantage of this approach:
In relation to the efficiency of the process, my
expectation would be that if as an alternative route this Committee
or whoever engaged lawyers and accountants to do a full investigation
[...] it would have taken a much longer time, perhaps two or three
years, not 12 months, and would have been hugely more expensive.
It is quite interesting that the FSA review team was a bit more
than 10 man-year full-time equivalent and the total cost of that
was between £2 million and £3 million. The PwC investigation
[which supported the enforcement case] cost very significantly
more than that, and that was focused exclusively on the enforcement
part of the exercise, not on the history, which probably is of
larger interest certainly in bringing the facts to light. So,
the cost consideration is also relevant.[137]
103. The original investigation undertaken by
PwC to support the possible enforcement action was reported to
have taken 19 months and cost £7.7 million.[138]
Mr Knight agreed with this assessment. He said that an advantage
of this approach was "speed and cost and getting the facts
out."[139] He
also noted that "experience shows, certainly in the case
of Companies Act inspections, that such inquiries take a very
long time, cost a great deal of money and often are quite noncommittal."[140]
104. The internal review approach may have time-and
cost-saving benefits, but Lord Turner did highlight in his evidence
to us that it was still a resource-intensive process for the FSA.
He noted:
One of the problems on the wholealthough I
think this process has been incredibly successful, the combination
of an internal process with external reviewers has produced a
high-quality reportit is very time consuming for a lot
of our best people. It is time consuming at a senior level. It
has been very time consuming for myself. So a bit of me thinks
that the best thing would be simply to pay somebody else to do
it at that stage.[141]
OBJECTIVITY AND THE ROLE OF SPECIALIST
ADVISERS
105. Cost and efficiency are clearly important
issues, and there is likely to be a benefit to the report authors
having existing institutional knowledge when examining failures
in their own organisation. The most difficult question thrown
up by having a largely internally written report is whether an
organisation is able to be sufficiently self-critical for the
report to be meaningful. The Governor of the Bank of England highlighted
this issue, saying:
With respect, one of the great weaknesses of the
FSA report was that it was the FSA writing a report on the FSA.
I do not think that that is a model for the future, and nor does
Lord Turner. In future, if you are going to have reports or oversight,
it is rather important that the people whose behaviour you are
overseeing are not actually members of the board responsible for
that.[142]
106. The Governor's comments go to the heart
of the question of whether an internal review can be sufficiently
objective to add value. An additional question is whether, even
if an internal review is objective, it will be perceived to be
so. Despite the Governor's claim that Lord Turner did not think
the FSA's Report into the failure of RBS provided a model for
the future, Lord Turner's own words seem to suggest otherwise.
In a letter to the Chairman of this Committee Lord Turner noted
that he believed the FSA's Report "should stand as an exemplar
of high quality, dispassionate and, when necessary, self-critical
analysis".[143]
107. Our specialist advisers agreed with Lord
Turner's assessment of the objectivity of the Report. Sir David
noted that he believed the Report was "adequately critical"[144]
and summarised his view of the fairness of the FSA Report as follows:
There is nothing [...] that has not been published
that in our view has any materiality or which if you had it would
lead you or us to reach a different view of the story, the narrative,
the account.[145]
Mr Knight acknowledged that "where an institution
reports into itself they do have the advantage of being able to
put their own point of view"[146]
but he felt that despite this the FSA Report "does state
the facts" [147]
and that the Report "is a good, fair and balanced summary
that hides nothing".[148]
108. Nonetheless, the FSA's work in this area
was improved by external oversight. In particular, a much greater
degree of objectivity in the Report appears to have been secured
by the work of the independent specialist advisers appointed by
the Treasury Committee. In a letter to the Chair of this Committee
Lord Turner highlighted the importance of the external reviewers
as follows:
The role of the external reviewers has been extremely
valuable ... if in future there are reports into major financial
failure which are produced by the regulator itself, I believe
that the device of external reviewers should be used to provide
challenge, variety of external perspective, and external assurance
that there has been an appropriately self-critical approach.[149]
109. Major changes were made to the report as
a result of the specialist advisers' intervention. They highlighted
five material areas in which they had suggested alterations to
initial drafts of the Report, largely aimed at getting fuller
and more detailed explanations of areas they felt were particularly
important. The five areas were:
- a fuller explanation of the
reasons for selecting the three areas for enforcement investigation;
- greater emphasis on the delegation responsibilities
of the RBS CEO and the adequacy of their discharge, in particular
in respect of the credit, sales and trading business;
- a fuller description of the nature and degree
of involvement of the FSA Board in setting or endorsing the relevant
policy approaches of the FSA executive during the review period;
- more detailed review and conclusions on the FSA's
response, even within the policy approach and framework at the
time, to the exceptional complexity, method of execution and risks
inherent in the ABN AMRO acquisition, given the seriously constrained
due diligence process that was undertaken; and
- a clearer assessment of the substantive functioning
as distinct from the formal process of the RBS Board, in particular
in relation to oversight of the very rapid balance sheet expansion
in the review period and the ABN AMRO acquisition.[150]
Both our specialist advisers were satisfied that
the FSA had adequately addressed the issues they raised in the
final Report. They noted that "while the structure, content,
editing and conclusions of the FSA Report are the responsibility
of the FSA, we were able to comment freely on all aspects of the
FSA's review and there are no material points on which our work
has led us to disagree with the FSA."[151]
110. The role of the external reviewers was important
because of the function they performed in commenting on the various
iterations of the FSA's Report during the drafting process. Their
role was also significant, however, because the very existence
of external reviewers and the knowledge of external oversight
is likely to have had implications for the behaviour of the FSA
reviewers, encouraging them to be more conscientious in ensuring
that the Report was a full and frank examination of the issues
relating to RBS's failure.
111. Objectivity of an internally authored report
can also be secured by ensuring that it is endorsed by the board
of the institution involved, thereby making board members individually
and collectively responsible for its content. This point was made
by Mr Knight:
I think it is absolutely vital if you go for this
model that the board or the governance of the organisation concerned
accepts, individually and collectively, responsibility for ensuring
that the report is fair. I think that is absolutely vital. That
is what they have done here. The board of the FSA have given us
an assurance that in their view this is a fair and balanced account.[152]
112. The FSA Report was reviewed in detail by
four of the FSA's Non-executive Directors, who were tasked with
"providing direct Board-level scrutiny of the Report and
of the independence and objectivity of the processes by which
it had been produced."[153]
Beyond that, the FSA confirmed in its Report that:
The Report as a whole, and the judgements made within
it, had been reviewed by the full Board.
On the basis of the quality assurance processes described
above and its own discussion of key conclusions and judgements,
the Board agreed to confirm to the specialist advisers that, in
its opinion, the Report represents a fair and balanced summary
of the evidence gathered by the FSA and by PwC during their review
of the failure of RBS, that it fairly reflects the finding of
the FSA's investigation and that it is a fair and balanced summary
of the FSA's analysis of its regulatory and supervisory activities
in the run-up to the failure of RBS.[154]
113. The FSA's Report into the
failure of RBS was largely written by FSA staff, with additional
scrutiny being provided by the Treasury Committee's specialist
advisers Sir David Walker and Bill Knight. We believe that this
model has proved successful in giving our Committee and the public
a reasonable degree of confidence that we now have a true and
fair picture of what went wrong at RBS. We also have a better
grasp of the failings of the FSA.
114. A report produced by an
organisation into itself will not be completely free from subjectivity.
However, the appointment of external reviewers in this case appears
to have improved the report and greatly improved its objectivity.
115. The work of the independent
external reviewers appointed by the Treasury Committee enabled
Parliament to scrutinise a powerful regulator in a new way. The
approach sets a precedent for the Treasury Committee in the future,
and it may also be of use to other select committees.
116. Although the FSA board
endorsed the Report, non-executive directors of the FSA should
have held the FSA's executive to account and themselves commissioned
a review of the Authority's performance, as routinely happens
within the private sector. The collapse of RBS should have been
a prime candidate for such retrospective internal review. We have
recommended in our Report on the Financial Conduct Authority that
legislation provide for the Treasury Committee to request retrospective
reviews of the future FCA's work. We would not, however, expect
a properly functioning board to need such prompting from Parliament
to conduct such reviews. We will expect non-executive directors
of the future PRA and FCA to ensure that regular reviews of performance
are undertaken and that appropriate governance structures are
in place to support them in this task.
The value of further reports
from the FSA into the crisis
117. As noted above, the FSA's report into the
failure of RBS has value in that it meets the need for public
accountability. When questioned about the value of the Report
to the FSA in terms of learning lessons, Lord Turner said:
If we go back to what the lessons learned from this
report are, many of them we knew already. The basic fact that
the capital and liquidity regimes were, to be blunt, rubbish,
we knew already, and we were putting them right. The supervisory
approach was wrong and we were putting that right.
When we produced this, I strongly urged all staff
members to read it, particularly those going to the PRA. We have
something here that all prudential supervisors, at least for the
next 10 years, ought to read as part of their training programme.
Indeed, all non-executive directors of banks ought to read it,
because I think, when you have a lengthy and, I believe, high-quality
report of what went wrong, there are a lot of lessons that you
can get out of it, and they just tell you the story of a bank
that made a collection of mistakes that reached a failure. That
is very important for people to read.[155]
118. Sir David supported this opinion, stating
that "having done this exercise, there emerged matters of
understanding that have been hugely beneficial for the regulator
[...] I would think the regulator has learned a huge amount from
this process."[156]
119. In acknowledging that there are "a
lot of lessons that you can get out of" the FSA's Report,[157]
Lord Turner seems to have had a welcome change of mind from his
earlier assertion that a report into the failure of RBS would
"add little, if anything, to our understanding of what went
wrong."[158] Recommendations
for further change to the supervisory structure, in addition to
proposals for change identified through earlier work, such as
the FSA's internal audit report on the failure of Northern Rock
and the Turner Review[159],
are identified at the end of each section of Part 2 of the FSA's
Report and summarised in Appendix 2A, Table 2.[160]
120. HBOS was another major bank which failed
during the financial crisis. Lord Turner committed the FSA to
the production of a report once its enforcement action had been
completed, stating that the FSA had:
Put in place a small data gathering team. They will
not write down anything that is a judgment, because we cannot
do that without potentially prejudicing the enforcement process,
but we are going through the process of gathering together the
files, doing some of the straightforward calculation analysis
that we did with RBS on capital and liquidity, having done it
before, so that as and when we get beyond the enforcement casebut
I do stress we have no control over the overall timescale of thatwe
will be in a position to launch it.[161]
121. On 9 March 2012, the FSA announced that
its investigation of the firm itself had been completed and that
the FSA judged that HBOS had been guilty of very serious misconduct.
Given the exceptional circumstances of the firm being part-owned
by the taxpayer, the FSA decided not to levy a fine, but instead
issued a public censure.[162]
On 12 September 2012 the FSA concluded its remaining enforcement
action in relation to HBOS when it fined Peter Cummings, former
executive director of HBOS plc and chief executive of its Corporate
Division, £500,000 and banned him from holding any senior
position in a UK bank, building society, investment or insurance
firm.[163] Following
that announcement the Treasury Committee wrote to Lord Turner
as follows:
We will require of the FSA the same comprehensive
assessment of the reasons for the bank's failure, and of the FSA's
conduct, as was case with RBS. External advisers, appointed by
the Committee, should again be employed during the drafting process
to provide assurance that the report is a fair and balanced reflection
of the evidence. We will need to discuss whom to appoint. The
report should cover the reasons for, and the consequences of,
both the Lloyds/HBOS merger and the earlier Bank of Scotland/Halifax
merger.[164]
On 28 September 2012 Lord Turner replied to the Committee
that:
On the report, the most important next step will
be to agree the Terms of Reference and governance arrangements.
The FSA Board has created a sub-committee to overview the development
of the report: this Committee will be chaired by Sir Brian Pomeroy
who also chaired the sub-committee which oversaw the production
of the RBS report, and who in the course of that liaised extensively
with Sir David Walker and Bill Knight. [...]
Your letter set out the Committee's desire to appoint
external reviewers, as with the RBS report. As you know, my letter
to you of 11 July 2011, which said that we believed we should
produce an HBOS review once we had completed the legal enforcement
[process], also stated that the external reviewers had played
an extremely useful role on the RBS report, and that we should
use this device again on the HBOS report. [...][165]
The Committee and the FSA will discuss further the
details of how the report on the failure of HBOS will be undertaken.
122. The FSA Report into the
failure of RBS, alongside previous reports on other aspects of
the financial crisis and pre-crisis regulation, highlights the
respects in which pre-crisis regulation was misguided. The document
will be of long-term value for those involved in the regulation
and corporate governance of banks. A similar exercise in relation
to the failure of HBOS will now be undertaken.
Reports from other bodies
123. In the absence of pressure from the Treasury
Committee the FSA Report into the failure of RBS would never have
been produced. Lord Turner asserted, however, that the FSA has
set out "more openly than any other financial authority"
the inadequacies of their approach prior to the financial crisis.[166]
124. HM Treasury has gone some way to addressing
this with the publication of an internal report on their performance
during the crisis entitled Review of HM Treasury's management
response to the financial crisis[167],
which this Committee will examine in due course.
125. The Bank of England has been much more reluctant
to undertake a similar 'lessons learned' review, despite multiple
requests from the Treasury Committee for them to do so. In a letter
to the Chairman of this Committee the Governor of the Bank of
England argued that "the way the Bank used the tools available
to it in the first phase of the crisis has been thoroughly reviewed
and that far-reaching reforms have been made."[168]
He noted that the only tool available to the Bank in dealing with
the crisis was its balance sheet and that:
The Bank's balance sheet, was, and is, used to achieve
two objectives: the implementation of monetary policy decisions
taken by the Monetary Policy Committee, and to provide liquidity
insurance to commercial banks. It proved challenging in the very
first phase of the crisis to meet either of these obligations.
In response, the Bank conducted a major review of,
and consultation on, the use of its balance sheet.[169]
126. The consultation to which the Governor referred
set out proposals for the development of the Bank of England's
market operations.[170]
It suggested improvements to existing operations which were designed
to respond better to the stressed market conditions prevailing
at the time. Following the publication of this document the Bank
implemented a number of changes to its operations. In addition,
a number of the extraordinary operations that were put in place
by the Bank, such as the Special Liquidity Scheme, were significant
in preventing further failures in the financial sector. The
Governor noted in his letter of 31 January 2012 to the Chairman
of this Committee that all of the actions taken by the Bank to
revise its operations since the crisis had been set out in published
documents.[171] While
this is the case, these documents do not constitute a thorough
review of the Bank's response to the crisis. This remains to be
done.
127. In the same letter the Governor hinted at
the two other arguments previously deployed by the Bank to suggest
that it should not be obliged to undertake a comprehensive review.
First, that many of the actions undertaken by the Bank during
the crisis were in fact decided upon and implemented by the Bank,
FSA and HMT so any review should not be done by the Bank but by
an external body examining all three members of the tripartite.[172]
Secondly, that while there was still a crisis continuing, it was
not appropriate to devote the time or resources to undertaking
an internal review.[173]
128. These arguments, particularly the latter,
may have merit, but they were significantly undermined when, on
21 May 2012, the Bank of England announced that its Court had
commissioned three reviews into areas of the Bank's performance
during the financial crisis. The reviews are being led by independent
external experts, supported by Bank staff, and cover the following
areas: the provision of Emergency Liquidity Assistance in 2008/9;
the Bank's framework for providing liquidity to the banking system
as a whole; and the Monetary Policy Committee's forecasting capability.[174]
They are expected to conclude in October 2012 and the Committee
will examine these reviews in due course.
129. HM Treasury has published
a review of its performance during the crisis, which the Treasury
Committee will review in due course. The Bank of England has also
belatedly announced a number of reviews examining aspects of its
own performance in this period. While this represents some progress,
it falls well short of what is required. A comprehensive review
of the Bank's role in, and response to, the crisis is needed and
we will return to this issue after publication of the three reviews
commissioned by the Court of the Bank of England. Moreover, by
waiting so long before conducting any review, the Bank of England
has diminished its value as a guide to better regulation for the
future. Any lessons learned as a result of even these limited
reviews will also only be available in a very late stage in Parliament's
consideration of the Financial Services Bill. Incorporation of
them into legislation may therefore be more difficult and this
is regrettable.
129 HM Treasury, HM Treasury Annual Report and Accounts,
2010-11, Certificate and Report of the Comptroller and Auditor
General, HC 984, July 2011, p89. The peak figure of £1.162
trillion is the sum of the cash outlay (e.g. for purchasing shares
in RBS and Lloyds) and the maximum support pledged (e.g. through
schemes such as the Credit Guarantee Scheme and the Asset Protection
Scheme) by the Government during the crisis, including amounts
that were not used. Schemes under which support was pledged were
not necessarily available at the same time, so the peak figure
of £1.162 trillion was not available at a single point in
time. Back
130
HM Treasury, HM Treasury Annual Report and Accounts, 2010-11,
Certificate and Report of the Comptroller and Auditor General,
HC 984, July 2011, p93 Back
131
Opinion, Financial Times, 7 December 2010 Back
132
Q 1 Back
133
Letter from Chairman of the FSA to Chairman of the Treasury Committee,
11 December 2011 Back
134
Q 88 Back
135
Q 90 Back
136
Q 189 Back
137
Q 16 Back
138
"Royal Bank of Scotland investigation: the full story of
how the world's biggest bank' went bust", The Telegraph,
6 May 2011 Back
139
Q 22 Back
140
Q 22 Back
141
Q 190 Back
142
Oral evidence taken before the Treasury Committee on 17 January
2012, HC 1753, Q 21 Back
143
Letter from Chairman of the FSA to Chairman of the Treasury Committee,
11 December 2011 Back
144
Q 53 Back
145
Q 11 Back
146
Q 16 Back
147
Q 16 Back
148
Q 52 Back
149
Letter from Chairman of the FSA to Chairman of the Treasury Committee,
11 December 2011 Back
150
Evidence to the Treasury Select Committee by Bill Knight and Sir
David Walker, specialist advisers to the Committee in relation
to the report by the Financial Services Authority into the failure
of The Royal Bank of Scotland', p 2 Back
151
'Evidence to the Treasury Select Committee by Bill Knight and
Sir David Walker, specialist advisers to the Committee in relation
to the report by the Financial Services Authority into the failure
of The Royal Bank of Scotland', p 2 Back
152
Q 21 Back
153
The Financial Services Authority, The failure of the Royal
Bank of Scotland: Financial Services Authority Board Report,
December 2011, p 18 Back
154
The Financial Services Authority, The failure of the Royal
Bank of Scotland: Financial Services Authority Board Report,
December 2011, p 19 Back
155
Q 189 Back
156
Q 49 Back
157
Q 189 Back
158
Opinion, Financial Times, 7 December 2010 Back
159
The Financial Services Authority, Internal Audit Division,
The supervision of Northern Rock: A lessons learned review,
March 2008; The Financial Services Authority, The Turner Review:
A regulatory response to the global banking crisis, March
2009 Back
160
The Financial Services Authority, The failure of the Royal
Bank of Scotland: Financial Services Authority Board Report,
December 2011, Part 2, and Appendix 2A, Table 2 pp 300-302 Back
161
Q 190 Back
162
"FSA publishes censure against Bank of Scotland plc in respect
of failings within its Corporate Division between January 2006
and December 2008", FSA Press Notice, 9 March 2012 Back
163
See http://www.fsa.gov.uk/library/communication/pr/2012/087.shtml Back
164
Letter from Chairman of the Treasury Committee to Chairman of
the FSA, 13 September 2012 Back
165
Letter from the Chairman of the FSA to the Chairman of the Treasury
Committee, 28 September 2012 Back
166
Opinion, Financial Times, 7 December 2010 Back
167
HM Treasury, Review of HM Treasury's management response to
the financial crisis, March 2012 Back
168
Letter from Governor of the Bank of England to Chairman of the
Treasury Committee, 31 January 2012 Back
169
Letter from Governor of the Bank of England to Chairman of the
Treasury Committee, 31 January 2012 Back
170
Bank of England, The Development of the Bank of England's Market
Operations : A consultative paper by the Bank of England,
October 2008 Back
171
Letter from Governor of the Bank of England to Chairman of the
Treasury Committee, 31 January 2012 Back
172
"Sir Mervyn King scrutinised as Bank of England orders review,"
The Telegraph, 21 May 2012 Back
173
Letter from Governor of the Bank of England to Chairman of the
Treasury Committee, 31 January 2012 Back
174
"Court of the Bank of England commissions a set of reviews
to learn lessons", Bank of England Press Notice, 21 May 2012 Back
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