Recommendation 121

Other witnesses complained about the inconsistent quality of supervision and the rigidity in the application of rules, linking the lack of flexibility and agility in the supervisory processes to the prevalence of junior staff in supervisory roles. Lord Blackwell noted: “The size of the supervisory teams and the relatively junior experience of those conducting the day to day interface with financial institutions means that many interactions demonstrate an overly rigid and risk averse application of the detailed rules.” 195 The rotation of supervisors