Storm warning on the governance of WAMU banks

By Cheihna Bounajim Cissé.

 

Governance ?! Everything was written or almost on this phrase « very trendy » which is flourishing everywhere. It is used by everyone and for everything as the magic ingredient; or simply as a bait to conceal the purposefully designed hook for catching small and large « fish » in the murky waters of corruption. Even those who challenge governance, not the concept but its bloat, use and abuse it in sententious statements and during licentious ceremonies.

Yet governance issues need to be taken very seriously. Everywhere, especially in banking. We can not engage in it with the intention of going around the track, the time to print his trademark, to fill his epaulettes and platelets of his establishment, to finish by telling a beautiful story to the collaborators, directors, shareholders and the media. And, later, deflate like a balloon to arrange with reality. Good governance can not be a shirt that can be changed at will and even free to wear and support. It is not, either, an option, an exercise bike where the leaders of the control structures gnaw their brakes, failing to find better. Governance is not straw or smoke, let alone smoke. It could not be a game, a matter of improvisation as if one were playing Russian roulette. It’s tough. It is to have been neglected and even forgotten, that the concept is back in force in banking regulations.

Governance is a whole. You can not put it in pieces, take the rewarding part and leave the « bone » for later. Recurrent revelations, repeated failures and other knife-strikes against him can not be a storm circumscribed in a glass of water. They will, sooner or later, with an amplified effect, affect the image and reputation of the credit institution. For the simple reason that they challenge trust, which is essential for building meaningful and lasting relationships among all stakeholders.

In truth, governance in banks in Africa is a real subject. And, she is ultrasensitive. Does this mean, on the grounds of a serpent’s prudence, that we must make a fetish of it? Not at all ! It is not because it is delicate that it should not be treated. « The height of caution is to have a leg cut for fear of breaking it one day, » said Swiss writer François-Rodolphe Weiss. And we must congratulate the WAMU Banking Commission for taking full measure of the situation by completely revising the supervision mechanism of the institutions subject to adapt to the new international context and the requirements of the sub-regional market

We used to say that « banking secrecy » should not turn the bank into a « secret box ». The bank, before being a formidable financial capital transformation industry, is first and foremost a service provider. Its vision, its strategy and its organization must be « centric », that is to say oriented « Customer ». It must therefore be « demystified » by presenting it as an open, transparent, available and accessible business. Those inside and outside who are preaching under the cloak that the bankers must keep quiet, and even hiding in their cozy comfort, far from the monetary and financial debate, are totally wrong. At least, it’s not our design. Moreover, most of them are proud to abhor the publications of Western bankers, and even to refer to them through generous passages swarmed during reunion sublimated by knowledge that is only praised.

It is increasingly difficult for an African banker to write about his profession! For several years now, we have been resisting frivolous conspiracy, pinpoint attacks and barely veiled intimidations, high-dose deprivation and sedation. Be assured, supporters as slayers, no concession will be made to treachery, trickery and other trickery. So please, do not fight the truth expressed; accept it, it may be a good company, you and those you claimed to defend. Good deed !


Introduction

July 2, 2018 will remain a historic date in the supervision of credit institutions operating in the WAMU zone. This is indeed the date chosen by the Banking Commission to launch the implementation of five important circulars, namely:

  • Circular No. 01-2017 / CB / C on the governance of credit institutions and financial companies of WAMU dated 27 September 2017;
  • Circular n ° 02-2017 / CB / C relating to the conditions of exercise of the functions of directors and senior management within credit institutions and financial companies of WAMU dated 27 September 2017;
  • Circular No. 03-2017 / CB / C relating to the internal control of credit institutions and financial companies in WAMU dated 27 September 2017;
  • Circular no. 04-2017 / CB / C on the management of risks in credit institutions and financial companies in the WAMU of 27 September 2017;
  • Circular no. 05-2017 / CB / C relating to the management of compliance with the standards in force by credit institutions and financial companies in the WAMU of 27 September 2017.
    Six months after a banking Eve more than difficult marked by the start of the new Chart Banking Accounting (PCB) and Basel prudential device (Basel II and Basel III) that credit institutions in the region have difficulty ingesting and digesting, here is what new, more stringent and demanding regulatory texts are coming in this time from the WAMU Banking Commission. No more freewheeling time! The golden age of freelance banks is over. The Supervisory Body decided to strengthen the supervisory and control mechanism of credit institutions.

It is true that the « banking meteorological services » had launched, since September 27, 2017 (date of signing of the new circulars), a storm warning on the entire banking system of the sub-region. According to forecasts, cumulus clouds should fade in favor of cirrus and arcus. Already, it begins to rain halberds. Call it what you want, storm, tornado, storm, typhoon or hurricane, this banking cyclone that I called « Circob » has just reached the African coast. At Uncle Sam, the levees were sufficiently elevated after the hectic passage of Basel III. In Europe, we continue to bite our teeth after the terrible financial crisis of 2007. There, we even whisper the arrival of Basel IV.

In the WAMU zone, in fragile and vulnerable economies, the cyclone has already reached the Saffir-Simpson Category 5 (highest intensity level). It began with a cyclonic depression, following the combined effect of the new prudential regime and the interaction with the new PCB. It could intensify from 2022, at the end of the transitional period. For example, on that date, no WAMU credit institution will be able to grant a single signature (a client or a group of related customers) more than a quarter (25%) of its core capital against a 75% at the end of 2017 and 65% currently. Like the risk division coefficient, the level of the solvency ratio has also been revisited. It should be at least 9% in four years, compared to 8% this year. This increase of 100 basis points is very significant, for at least two reasons. First, the basis for calculating the ratio has changed completely. To cite just one example, instead of « effective own funds » in the old scheme, it is now more restrictive « Tier 1 » own funds. The difference for some banks is a ratio of 1 in 2.

On the other hand, according to the prudential situation of the banking system of the WAMU provided by the Banking Commission in its last annual report, 12 credit institutions (out of 113), representing 8.6% of the banking assets of the zone, were below the minimum threshold of the solvency ratio. At the community level, there were two countries, namely Côte d’Ivoire (7.9%) and Togo (5.8%), which did not meet the minimum level required (8%). These two countries accounted for 37.6% of the WAMU banking market at the end of 2016.

Unlike Katrina, Mitch or Andrew, Hurricane Circob should be beneficial and even life-saving for the banking system in the sub-region. Through its gusts of wind, it dusted off a supervision device, more than a quarter of a century old, which showed its limits, even if it was partially revised in 2001 and 2011.

Before going into the thick of the subject, allow us a quick overview of the inventory. It is provided by the annual reports of the Banking Commission of WAMU.


I. State of play: A very fragile banking governance

On a regular basis, the Supervisory Body emphasizes in its annual reports the serious shortcomings that it has observed in the application of regulatory texts, particularly those relating to governance issues.

Thus, during the 2016 financial year, the WAMU Banking Commission made important decisions regarding administrative measures and disciplinary sanctions against several credit institutions. We can mention, among others:

  • the ex officio resignation of a Chairman of the Board of Directors, in view of the « grievances raised against him concerning the perception of numerous benefits in the form of remuneration and the daily interference in the management of the establishment in violation of texts in force « ;
  • the resignation of a Director General ex officio on the grounds of « irregular acts committed committing his personal responsibility »;
  • issuance of 8 injunctions, an increase of 60% compared to 2015. These administrative measures concerned credit and microfinance institutions located in Benin (1), Burkina Faso (2), Niger (1), Senegal ( 3) and Togo (1). They aimed, inter alia, to « ensure risk management in accordance with the regulations in force », and to « improve governance and strengthen the internal control system ».
  • the hearing (simple) of several bank managers (4), warnings to 9 credit institutions and the maintenance of the close supervision of 2 institutions subject to Burkina and Niger.

In 2015, the CBB issued a ban on the administration, management or stewardship of WAMU credit institutions and decentralized financial systems against a former Director General, because of « serious deficiencies in the management of the institution relating to acts of mismanagement that engage his personal responsibility ».

In 2014, the WAMU Banking Commission imposed 6 blames on 3 banks located in Mali, Niger and Togo respectively and 2 microfinance institutions in Côte d’Ivoire and Togo, as well as the head of a decentralized financial system of Côte d’Ivoire. According to the Supervisory Authority, these decisions were taken because, among other things, « the numerous shortcomings identified in the governance, risk management and other assets and acts of mismanagement ». It pronounced 3 ex officio resignations concerning the Provisional Administrator of a bank installed in Togo, considering « acts of mismanagement directly engaging his personal responsibility and carried out under conditions seriously violating the rules of governance (…) thus good practices for sound risk management, « the Director General of a decentralized financial system in Togo, due to » irregular acts of management relating to the award of significant bonuses, bonuses and gratuities not provided for by the remuneration policy of the institution as well as false declarations of diplomas made to the National Authorities and control tainting his reputation « , the Chairman of the Board of Directors of a microfinance institution established in Côte d’Ivoire, on the grounds of  » Irregular acts committed, relating in particular to the use of the resources of the institution to his personal profit and the cashing of checks in the name of the institution in his savings account « . During the year, the Banking Commission even imposed the supreme sanction (the « withdrawal of approval ») on a bank in Côte d’Ivoire, particularly with regard to « the persistence of serious breaches of banking regulations and the lack of prospects for recovery « .

Rest assured, you read well and you are well in the financial system, supposed to be a strongly regulated and protected area: « false declarations of diplomas », « use of the resources of the institution for its personal profit », « cashing of checks in the name of the institution in his savings account « , » many benefits in the form of remuneration « , » daily interference [of a PCA] in the management of the institution « , and so on and best.

Let’s stop at this level, and allow some simple questions to air our mind:

  • Who proposed and named the leaders who made the incriminated acts?
  • Why the Board of Directors, so quick to distribute the discharge, did not make the necessary decision by carrying out the necessary verifications?
  • The Auditors, report high as three kneeling apples, they refused to certify the accounts, in view of serious failures found in the governance and internal control system?
  • Do the revealed facts come from spontaneity, from providence, or have they lasted for months or even years?
  • Why have legal and regulatory alerts not worked?
  • Where were the internal and external control structures at the time of the facts?

II. Major innovations of the new supervisory framework
A) – In respect of the Board of Directors

Gone are the days of bank CEOs where only one person can hold the positions of Chairman of the Board and CEO, accumulate gains and profits, trammel the governance of his company, and end up concealing accounts and miscounts. The Banking Commission has removed all ambiguity on this point by cutting for the dual system (dissociated governance) to the detriment of monism (reunited governance).

According to Article 16 of the Circular on Governance, the Chairman of the Board of Directors must be a « non-executive director or an independent director ».

 

Gone are the days of the administrators, with the confused competence and / or the diffuse availability which discover or read, very often, the files in the room of the council. From now on, the credit institutions’ board of directors must be composed of proven skills. Article 12 of the Circular on Governance states: « The members of the deliberative body must have individually or collectively appropriate skills in particular in the areas of credit operations, financial analysis, information technology , strategic planning, governance, risk management, internal control, capital markets or compensation policies.

The members of the deliberative body, taken as a whole, must: (a) have a good knowledge of the economy and the markets in which the institution operates; (b) control the legal texts in force governing the activities of the institution in the WAMU and in the countries where its subsidiaries are located. In addition to article 13 of the said circular: « The deliberative body must be empowered to ensure that the directors appointed by the shareholders are qualified for the position ». Better still, even after their appointment, the directors must undergo continuous training: « The institution is obliged to set up continuous training programs for the members of the deliberative body or to take any measures to ensure access to the knowledge necessary to fully exercise their responsibilities (Article 14)  »

Gone are the days of « little arrangements with friends », transforming the board of directors into a « registration chamber » of the decisions discussed and agreed around the petit feu petits fours. The dissonant voices are rejected at the first opportunity. The Supervisory Authority wanted to be very clear on the subject. In the Circular on Governance, it states in Article 13 that « the members of the deliberative body have obligations vis-à-vis the interests of the institution as a whole and this, regardless of the authority that the appointed ».

More specifically, Article 16 stipulates that the chairman of the board of directors must ensure « the expression and the examination of divergent opinions ». Thus, « directors appointed by shareholders with dominant influence must maintain their impartiality and fully exercise their obligations of diligence and loyalty vis-à-vis the institution (Article 41) ».

In addition, the Board of Directors must « ensure that one person or group of people does not dominate the deliberative body to the detriment of the interests of the institution as a whole » (Article 24). Even better, in the new supervisory system, independent directors formally emerged to balance the stakes and protect the interests of the minority: « To reinforce the impartiality and objectivity of its decisions, one third of the members of the It must be composed of independent directors (Article 10). They must not have, directly or indirectly, with the establishment, a business relationship in progress or during the four previous years (Article 11).

Gone are the days when the bank administrator’s job was highly coveted for trading in influence, dragging tons of slates without worrying about erasing them. From now on, the Banking Commission obliges each director to submit « before taking office and annually to the deliberative body a declaration on honor, in which he attests, in particular, not to have outstanding debts in a credit institution of the WAMU (Article 40 of the Circular on Governance) « .

Article 42 further states that « members of governance bodies shall not be in default of payment on their commitments to the institution or in a banking ban in the WAMU. In such a case, they must be suspended from their duties. The Banking Commission must be informed by the Chairman of the decision-making body as soon as it arises « .

Gone are the days of administrators « businessmen » who could content themselves with soft observations on the management reports of the General Management, in exchange for lucrative contracts of service. « Before taking office and every year during his mandate, the director submits to the deliberative body a declaration of conflicts of interest relating to the links of any kind that he maintains directly or indirectly with the institution, its directors , its partners, its competitors and its fifty largest customers (Article 40 of the Circular on Governance) « .

Gone are the days when an administrator could make the « council buissonnier », being represented almost ad vitam aeternam, or by immersing himself in a silence almost deafening during the exchanges and the deliberations, while gathering in the passage of thick bundles of notes curiously called formerly « tokens of attendance », not to arouse, certainly, the excitement of some curious. Article 15 of the Circular on Governance resolved the question: « The deliberative body shall enact measures to ensure the presence and effective participation of its members in meetings. (…) The Banking Commission may require changes in the composition of the deliberative body if it finds that some of its members are not fulfilling their obligations (…) « . The Banking Commission has even provided, beyond the mere reading of the minutes of the board of directors which must be communicated to it, to « participate, as an observer, in the meetings of the deliberative body when it considers it necessary « .

B) – Under the Directorate General

Gone are the days of the general directors of « full powers » who allowed themselves, without striking a blow, hiring at a high price, based on considerations very often far removed from the real concerns and needs of their companies, and which are astonishing after the pace of the « common house »: a GNP that struggles to get out of the ground floor while the coefficient of exploitation campe penthouse. The Supervisory Authority has obliged the Board of Directors to « monitor and evaluate the performance of the main members of the executive body (Article 8) ». « Executive body » means « all the structures that contribute to the day-to-day management of an institution and ensure the effective application of the orientation of the activity defined by the deliberative body. In particular, members of the executive body are the Chief Executive Officer, the Deputy Chief Executive Officers, the General Secretary and the heads of the control functions (Article 3) « .

No more time for liners – these second knives without a blade – and even interleaves that scrape into the folds of the organization to the point of creating cracks. A bank CEO, as part of an external growth operation, challenged his colleagues on the meaning of the « binomial ». The quickest of them, and by far the most concerned, replied spontaneously: « A pair is two monomials ». Fate later decided to reverse the roles. The hour of responsibility has come. And for those who still doubt it, they will be able to make a happy reading of the new Circular on governance: « For the leaders, the Banking Commission is pronounced, on the one hand, on the competence of the persons approached with regard to the criteria of diplomas and of professional experience defined by the law regulating banking for the non-nationals of the UMAO and on the other hand, on the morality and the absence of condemnation leading to the prohibition of exercise envisaged by the aforementioned law ( Article 14) « .

C) – As control functions

Finished the time of the Director General to the « hegemonic powers » where the functions of control are put in the pillory. In the various management committees, with the composition and rules of procedure as profuse as they were diffuse, the will of the chairperson was binding on all members who were kept at a safe distance by his discretionary powers of sanction, retaliation and dismissal. And his simple opinion (even wobbly and radical) could be final decision. All this is a thing of the past.

The Banking Commission makes it clear that the Chief Executive Officer must « respect and promote the independence of the control functions and not interfere in the exercise of the responsibilities devolved to them » (Article 27 of the Circular on Governance). Better still, the heads of the control functions are now linked to the deliberative body which is responsible for their selection, supervision of their performance and their dismissal (Article 30, paragraph 1). Specifically, the heads of the control functions of the bank group subsidiaries are hierarchically and functionally dependent on the control functions of the parent company to which they belong and report.

They must also report to the governing bodies of their institution (Article 30 (2)). Thus, the appointment, transfer or dismissal of those responsible for control functions must be subject to the prior approval of the Board of Directors, on a duly motivated proposal from the Chief Executive Officer or the Audit Committee. These decisions must be brought to the attention of the Banking Commission (Article 31). The latter may summon each person in charge of a control function to examine any subject relating to its tasks and legal provisions. (Article 30 (4))

Gone are the days when the control functions were perceived as « garages », where any change in these services was perceived by the person concerned and his colleagues as a sanction. Article 16 of the Internal Control Circular removes any ambiguity on this point by highlighting the control function: « Each internal auditor must have the knowledge and know-how necessary to the exercise of his responsibilities. The internal audit function must collectively have sufficient competence to examine all areas of the institution’s activities. The institution must make arrangements for the auditors to keep their knowledge up to date.  »

The Banking Commission has even provided that the Board of Directors meets and exchanges periodically with the heads of the control functions (Article 7 of the Circular on Governance). The Circular on Internal Control is more explicit in Article 4. The deliberative body must « review, at least once a year, the effectiveness of the internal control system based in part on information provided by the function. internal auditors, the statutory auditors and the Banking Commission; and mandate, at least every five years, an external quality assurance review of the internal audit function « . Once again, the Circular on Governance states in article 29 that « each control function, placed under the authority of a separate manager, must (…) be endowed with competent and quantitatively sufficient human resources to carry out its mission. « . Article 31 introduces a major innovation by removing from the perimeter of the Directorate General staff movements within Internal Audit: « The appointment, transfer or dismissal of the head of the internal audit function and that of the auditors must be subject to the prior approval of the deliberative body, upon a duly motivated proposal by the Audit Committee. These decisions must be brought to the attention of the Banking Commission « .

Gone are the days when financial information about banks was inaccessible to the public and even hidden from the majority of staff. ICTs are there, Basel II and III also, it remains only banks to employ it and ultimately to deploy. The Banking Commission requires them to do this. Indeed, according to the Circular, « the governing bodies must ensure the timely dissemination of accurate information on all significant matters relating to the institution, including its shareholding and governance » (Article 47). « The information must be accessible on the institution’s website, in its annual and periodic financial reports and by any other appropriate means » (Article 48). The Internal Control Circular states in its Article 12 that « the information and communication channels established within the establishment must allow any staff member to have the information he needs to carry out control activities which assigned to him.  »

Better, and this is rare enough to be stressed, the Banking Commission has instituted and protected the role of « whistleblower » in credit institutions. Article 44 of the Circular on Governance provides a framework for this new mechanism: « The deliberative body must ensure the establishment of an internal mechanism for collecting information on dysfunctions. This mechanism must allow any actor of the establishment to communicate without delay, directly, confidentially, and without following the chain of command or indirectly, through the internal audit or compliance functions, practices contrary to Code of Ethics and any facts, actions, actions or circumstances that may affect the interests or reputation of the institution. The system must be known by all the actors of the establishment and integrate mechanisms according to good practices to ensure, as soon as possible, the taking of corrective measures following the information on the malfunctions. It must also protect the anonymity of whistleblowers and prohibit any form of retaliation.


III. And corruption and witchcraft?

Two issues of real gravity for the financial ecosystem have not been explicitly addressed in the new regulatory framework. This is corruption and the practice of witchcraft in banking. This means that everything is not perfect yet. Who can claim it? However, by adopting these new dissuasive, persuasive and curative regulatory measures, the Supervisory Body has made a major step towards stabilizing the banks, strengthening their governance and stabilizing the financial system of the zone.

Corruption is today an open secret, as it has become widespread and commonplace in all sectors of the continent’s economic and social life. So much so that she invited herself to the 31st Summit of Heads of State and Government of the African Union (AU), as the main theme of the meeting: « Win the fight against corruption, a sustainable path to transformation of Africa « . After that, who can reasonably believe that such a country or sector in Africa is spared by the pandemic of corruption? The subject was touched on in section 43 (« Code of Ethics ») of the WAMU Governance Circular. It could have been deepened by including, inter alia, the declaration of assets and conflict of interest, which should be subject to all bank managers (in the regulatory sense of the term), with an annual update extended to their family, with substantial resources given to the Compliance Officer (or the Ethics Officer if there is one) to investigate to ensure the authenticity and completeness of the property that has been declared. Other texts in the form of instructions can remedy this.

The subject of witchcraft (in the broad sense of the theme) is taboo and very sensitive in intellectual circles in West Africa. In the discharge of the Banking Commission, he could hardly be treated in the new supervisory framework. South Africa has been a pioneer in this area. Since then, many years have been teaching witchcraft. In this country, there are more than 200,000 « sangomas » (mystical healers) legally recognized. According to some sources of information, more than 80% of the South African population visit a sangoma more than three times a year. On March 20, 2017, the Rainbow Nation reached a new milestone by opening the first ever public witchcraft school on the continent. According to its initiators, this institution sets itself the goal of « training sorcerers and awarding degrees in science in witchcraft ». The country’s authorities have justified the creation of this school in order to clean up and promote the witchcraft sector: « Just like engineers and doctors, as well as pastors who go to universities to learn more about their profession. witches and sorcerers will have to take training to better use their gifts accordingly.  »

Zambia has just walked in the same vein with funding from UNESCO. Last November, the Zambian Minister of Higher Education declared that research and the study of witchcraft are « a science that can be used productively for the good of the country ». On the « Old Continent », supposed to be for many the receptacle of rationality and the crucible of Cartesian logic, since the beginning of time, metaphysical sciences and white magic have been taught. For example, in the South of England, students and managers come from all over the world to attend the Sorcerer Apprenticeship courses. At the witchcraft school of Bothwell, behind the walls of Herstmonceux Castle, immersion in the world of witchcraft is offered at a golden price. You have to pay between 600 and 1000 euros per person for three days of training.

In West Africa, witchcraft remains the prerogative of the mythical and the mystical. Yet its banking sector, like other parts of society, does not escape this phenomenon. Under the cloak, it is difficult to find a banker who could not tell and tell « his incredible stories, » as hallucinating as each other. Yet, in public, one kicks in touch, jaw clenched and face closed, feigning to ignore ignoring oneself and others, pots and cans, decoctions and lotions, intoxicating and captivating fragrances that smoke and smoke, these daily ritual baths, these loudly murmured litanies, those nocturnal and diurnal visits to the oracles, those gris-gris, amulets and talismans carefully concealed in rings, bracelets and even … belts. And so on and of the best. All this under the predictions of the geniuses supposed to assure power and knowledge, wealth and nobility, protection and affection, and tutti quanti.

So much so that one no longer believes in the strength of his neurons but rather in the effectiveness of his alms. In this exercise, some have been able to forge impregnable positions. Who rubs it, pricks it, one warns in the waterside. The victims of their imprecations and their execrations, hold as their extraordinary health shoulder sling, wandering between city practitioners and traditional healers.

The places of sacrifice and offering are not counted anymore in the villages as in the center of the city. The rocky banks of streams, hillsides, tree trenches, road crossings, anthills and termite mounds, in short, all the sacred places that are supposed to house the peninsties of the most formidable demons, are stormed. by the soothsayers, the cattle and the sheep. The blood flows, the milk flows, the customer collapses and the diviner breaks free. And ubiquitous scenes like this, worthy of the famous Bollywood films, can not be counted.

In truth, the practice of witchcraft, lato sensu, is an essential parameter to integrate into the management of banks in Africa. A bank executive, very knowledgeable about the mysteries of his profession, defined the bank as the « crossroads of all temptations ». He could not say better. Some of his colleagues have locked themselves into denial, others have tried to minimize the reality, almost all have left the scamps and ponder the mysteries of places once touted today haunted since itself disillusioned. Another manager, who did not care about these two-ball stories, had to change his mind by shooting himself in the foot. We will try to raise a corner of sailing on these different topics in our next books (« The Banker and the Wizard » and « Fables of the banking governance »), through a hundred real stories collected and treated for nearly three decades of professional life. In the meantime, for those who might be tempted to compliment or be innocent, here’s a taste of the sporty odyssey:

« A manager of a banking establishment, the dishes in his pocket, regularly engaged in very strange practices. For this dandy, religious faith was not incompatible with the observance of certain traditional practices. A sunny Sunday morning, he sacrificed to a well-deserved rest to head his offices. Before getting into the car parked at the door of his sumptuous abode, he sacrificed to a ritual gesture that had become almost habitual: he threw an egg behind him and in front of another, while making sure to chant a jingle. The guards twisted their necks to the point of catching the torticollis, lest they arouse the « boss’s » wrath. So reassured, it took place comfortably in the back of his limousine, accompanied by his faithful driver somewhat accustomed to his abruptness. Arrived at the bank, contrary to his habits, he asked to drive him in the backyard. Surprise! Still camouflaged at the rear of the vehicle with the windows darkened, he swallowed the place in one gulp. At the sight of the strange merry-go-round, the fayots came running to, certainly, bring comfort and comfort to the boss. They were unceremoniously invited to be occupied. The salamalecs to be pulled off the boots are postponed. As what Coluche may be right: « The guardians of peace, instead of keeping it, they’d better fuck it! « The horizon thus cleared, our DG made out of the trunk of his car strange parcels containing … salt with pull-larigot. With a firm and determined step, he took one of the bags, under the ribulant eyes of his factotum, who would have liked, at the moment, to be edentulous. Wasted effort ! He will carry, for many years, the burden of his sight hanging on his tongue. On the recommendations of the oracles supposed to supervise the remote operation, he began to « season » (sorry to salt) the soil of the precious product, not to melt the snow – there is none in this part of the world – but for it seems to exorcise his demons who, driven from his office, had taken their place in the bank yard …  »


Conclusion

The WAMU Banking Commission had a fine nose and a keen eye, breaking the paradigm of the regulatory framework. It introduced major changes in the banking supervision system to prevent, and if necessary correct, any deviant behavior of the executive and deliberating bodies of credit institutions. On this point, the advent of Basel standards in the area has been a happy pretext. Without a doubt, the objective in terms of governance is the integrity and moral rectitude of bank managers, through the establishment of a culture of accountability and accountability. This is called exemplarity: to serve, not to serve, even less to enslave. For the French Nobelist Albert Schweitzer: « The exemplary is not a way to influence, it is the only one ». His compatriot, the university practitioner Hervé Sérieyx prolongs: « To be exemplary it is at the same time to be economical of its remarks, to say only what one is decided to do oneself, and to engage in what the one says. The former leader of the Lesieur group continues: « How can we give meaning to others when we are ourselves deprived of it, when no system of values ​​forces us to stand up and to go beyond ourselves? (…) Hollow leaders, reducible to their technical skills alone, this is noticeable almost at first glance. At the time when the stripes, the titles and the statutes still impressed, they could easily remain at the head of pyramidal organizations. Henceforth, they are incapable of giving breath, life, soul to networked organizations, and their authority there appears purely formal.  »

Obviously, in the banking system of the sub-region, he blows a wind to decorate buffaloes and each actor caulked in trenches caulked heals his habitus. A Burkinabe wisdom teaches us: « When the canary breaks on your head, you have to take the opportunity to wash yourself ». Beware of submissive establishments that would venture to brave warnings and storm warnings! At this time of heat wave, we must especially hydrate the « old people » (historic banks) and « young children » (new banks). It is even necessary, if necessary, to wake them at night (after the departure of the customers) to make them drink water, a lot of water. In the same way, to avoid flooding during this wintering period – something simpler but more complex – the foundations of bank buildings (with a substantial contribution of equity) must be reinforced or evacuated. exposed (by decreasing less profitable assets).

The coming months will be decisive for the WAMU banking sector. Adapting or being absorbed remains the only rule that is right for a bank. Let us wager, conjure and adjure that the new regulatory requirements can contribute to the strength and stability of the banking industry on the one hand, and the banking and financing of the economies of the subregion on the other. However, we must remember a primary truth. Whatever the quality of the texts and the robustness of the supervision, nothing can stop a bank manager decided to pass between the drops. In one way or another, he will spread the interpretations of the « soft parts » of the new regulations, even if he will later pay the price of his business. Therefore, the independence and the proper functioning of the control functions must be constantly monitored. And it is not only the Supervisory Authorities (Banking Commission, Central Bank, Ministry in charge of Finance) to make sure of it and to worry about it. It is first and foremost the responsibility of the internal governance bodies of the credit institution. And in this exercise, the Statutory Auditors are strongly challenged in their legal role of whistleblower.

To mimic a French ecologist, yes to a fight governance, no to a governance of blows. The sages recall these recommendations of common sense: « Whoever drinks without thirst will vomit without effort » and « who kills drunk is hanged sober ». Let the leaders hold it for themselves!


About the Author

Cheickna Bounajim Cissé, the emerging.

Former member of the Basel Scientific Committee of FAPBEF-UEMOA, he is an economist and essayist. Holds an MBA from the University of Paris Dauphine and IAE Paris (University Panthéon-Sorbonne) and holds a professional degree in Political Science and Social Sciences – option Journalism – from the French Institute of Press (University Panthéon-Assas), he has a Master’s degree in business management from ENA in Bamako and a postgraduate degree in Banking (ITB – CNAM of Paris). He is also the author of several publications and is a contributor for several media. His latest book « Building Emergence, a Pact for the Future » was published in October 2016 by BoD.

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