Recommendation 126

However, low aggregate turnover does not necessarily guarantee continuity in the important supervisory function. Indeed, David Bailey, Executive Director for Prudential Policy at the PRA, noted that staff rotations are inherent to the PRA’s supervisory approach: “We need the supervisors to turn over on individual firms. We do not need that on a frequent basis, but they need to turn over after some time to prevent them getting too close and to make sure that there is appropriate independence, challenge and fresh thinking.” 203 Rotating supervisors has an important function in preventing regulatory capture, however, this must be balanced against the disruption to firms posed by the frequent rotation of supervisors.