I would be effectively barred from commenting on consumer issues. If I thought that I could achieve something from the inside, it might be worth doing that. But what are the chances of achieving anything?
Here is an extract from the Code of Ethics for the members of the Commission:
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Members may speak publicly, or publish items, in a personal (or other non-Commission) capacity on matters
other than those relating to the Central Bank and its functions. If doing so, a member should make clear that they do so in that particular (personal or other nonCommission) capacity and take care to avoid any adverse consequences or perceptions of the Commission or the Central Bank arising from any such public engagements."
I believe that heads should roll at Ulster Bank for the way in which they dealt with Niamh. Could I say this in public if I were on the Commission of the Central Bank? Or would it be more effective for me to say it inside the tent rather than outside the tent.
I have been very critical of the Central Bank for misleading the public on mortgage rates in Ireland. As a Commission member, would I get to see that report before it was published? Probably not.
They have handled the tracker rate issue incompetently. Could I say that if I were a member of the Commission?
"Role of the Commission
The Central Bank Commission (the Commission) has the following statutory functions: management and control of the affairs and activities of the Bank; ensuring that the Bank’s financial regulation and central banking functions are coordinated and integrated; and ensuring that the statutory powers and functions conferred on the Bank are properly exercised and discharged. In addition, the Commission has adopted its own terms of reference, which sets out how it can best deliver on those responsibilities.
The Central Bank Act 1942 (as amended) provides that any of the statutory functions may be delegated by the Commission to the Governor, a Deputy Governor or an employee of the Bank. In the interests of the efficient and effective management of the Bank and the exercise of its powers and functions, the exercise of most of the Bank’s statutory functions and powers are delegated to the management members of the Commission. Where functions are so delegated, the responsibility and accountability for the performance of these functions lies with that management member. However, the Commission, often through its three committees (Audit Committee, Budget & Remuneration Committee, and Risk Committee), monitors and reviews the performance of management members in exercising these functions and powers and examines the Bank's internal controls. In addition, where operational matters are brought before the Commission for decision, the Commission ensures that the Bank is acting in an appropriate manner consistent with its statutory functions and powers.
The Commission engages with management members on issues of strategic importance to the Bank (other than ESCB functions) and advises, supports and constructively challenges them as appropriate. It also contributes to the formulation of a strategy to allow the Bank to achieve its statutory functions and it reviews the Bank's performance in relation to this strategy."
I know that I would be in a minority of one on many, many issues. Having said that, Alan Ahearne and John Fitzgerald are very good guys and independent in their thinking. But I am not sure if I could persuade them that consumers matter.