excluding credit unions ), certain insurance undertakings and investment firms and incoming third country branches of these firms. taking into account nature, scale and complexity, it is intended to apply a proportionate approach to low - impact - rated in - scope investment firms and incoming third country branches. 7 in this regard, a reduced number of prescribed responsibilities are applicable to such firms. all other elements of the sear apply, including statements of responsibilities and the management responsibilities map. the central bank will have power via regulations to rollout the sear to other sectors in due course. it is our intention to increase the scope of application of the sear over time, with lessons from the initial roll - out to be incorporated as the scope is extended. in the meantime, our view is that there is much in the spirit of the sear that firms not initially falling within scope should recognise as aligned with good quality governance. responsibilities we have designed the framework such that, for consistency and coherence, the roles to which the sear applies at inscope firms align with those existing pcf roles to which the f & p regime applies. as is the case under the f & p regime, firms will not be required to create new roles. therefore, while bringing enhanced clarity, the sear is not expected to alter the existing governance structures of well - run firms. there are two main types of responsibilities imposed under the framework : 1 ) inherent responsibilities : these are the responsibilities which automatically align to any given pcf role at an in - scope firm. our proposed description of such inherent responsibilities is set out in the draft sear regulation. 2 ) prescribed responsibilities : these comprise a list of responsibilities which it is proposed that each in - scope firm must allocate among individuals in pcf roles. again, our proposed list of prescribed responsibilities is set out in the draft sear regulation. while firms must allocate all applicable prescribed responsibilities among pcfs at in - scope firms, the central bank does not intend to be overly prescriptive in terms of the allocation of prescribed responsibilities to specific pcf role - holders. this approach gives firms the flexibility to allocate responsibilities in a manner that accommodates different business models and organisational structures. non - executive directors one aspect that has generated some debate already is the proposed inclusion of non - executive directors ( including independent non - executive directors ) within the scope of sear. we have given this careful consideration. it is important to recognise that non - executive directors

, the standard deviation of inflation in ireland minus inflation in the uk in this period approached 2 percentage points – even when the war years are excluded. gerlach and stuart ( 2014 ) discuss irish monetary and price data for those years. bis central bankers ’ speeches would augur poorly for an economy too closely linked with it. yet, lacking a clear alternative policy, and fearful of switching to too tough a regime, the irish authorities had left any decisive step to change currency policy on the long finger. 4 suddenly the landscape changed when, triggered by the french government ’ s desire to rejoin the currency “ snake ” arrangement according to which continental currencies maintained a joint float against the us dollar ( the chart of exchange rate movements thus tracing a snake - like appearance ), a movement among leading european politicians to create a ‘ zone of monetary stability in europe ’ forced the irish government to make a choice. a new type of exchange rate regime, tying ireland into the seemingly more vigorous, less volatile, continental economies with their recent record of lower inflation seemed to be on the cards. should the irish government join the exchange rate mechanism ( erm ) of this new european monetary system ( ems ), even at the risk of having to break the sterling link ( if the uk did not join )? perhaps the new arrangement really would represent something different and more acceptable that the austere snake – tougher than the sterling link, but weaker than the latter. after some initial hesitation, largely motivated by the fear of the regime being too strict, but eased by some ad hoc european subsidies ( also granted to entrants italy and denmark ), ireland joined the erm, while britain stayed out. the outcome did not correspond to expectation. the erm proved to be a much softer or more lax exchange rate regime for ireland than the sterling link. not only did sterling – still the main trading partner currency – strengthen as a result of north sea oil and the anti - inflation policies of the thatcher government, but the erm itself failed to live up to its branding as a zone of monetary stability. in particular, with its many realignments, the erm lacked a “ nominal anchor ” which would ensure price stability. this allowed less disciplined member states frequent opportunities to offset wage competitiveness drift with adjustments to the peg. devaluations of the irish pound against the dm – core currency of the erm – were thus more frequent than had been envisaged, occurring about once a year in