The report published yesterday by the financial regulator is the first milestone in the inquiries sparked by revelations that AIB charged foreign exchange customers a rate in excess of that notified to the authorities.
It is a good start - the problems have been identified and those subject to overcharging will be repaid. However, many other questions remain to be answered and will now be examined by the regulator and the investigators it is overseeing, most significantly why foreign exchange overcharging continued for eight years and how senior executives came to benefit from an offshore investment account.
The tone and content of the message coming from AIB yesterday are to be welcomed. The bank appears to be sincere in both its contrition and its attempts to make amends. Mr Dermot Gleeson, who took over as chairman last year, should be given some credit for the bank's initial response. The defensiveness and aggression that have characterised its response to previous scandals such as the underpayment of DIRT and the Allfirst fraud were refreshingly absent. In excess of €34 million is to be returned to consumers.
We should not lose sight of the fact that the chances are that were it not for an anonymous whistle blower none of the catalogue of failings to which the repayments relate would have seen the light of day. Nor might we ever have heard of the Faldor controversy involving an offshore fund managed by the bank's investment arm.
Yesterday's report from IFSRA is an interim report and as such only sets out to establish who may have been overcharged and by what amount. It will not be until later in the year - when the independent accountants delving into the issue have reported - that we will have a clearer idea of how the bank failed to notice that it was applying the wrong charges, for over eight years in some cases.
The autumn should also bring the results of the investigation into AIBIM, the bank's investment arm. The issues involved here are potentially even more damaging as they relate to alleged tax evasion by senior executives of the bank. It is only at that stage that we will be in a position to judge whether - as the bank claimed yesterday - there was no systemic failing, but instead a series of unfortunate and unrelated errors and omissions. At that stage, something more than bowed heads may be needed to restore the bank's reputation.
In the meantime, we will have seen the High Court's inspectors report into National Irish Bank, due to be published next Friday. Court proceedings yesterday indicated that the inspectors have uncovered extremely serious malpractice both in customer overcharging and the facilitation of tax evasion. The events at both banks have damaged the sector and seriously undermined consumer trust. Yesterday's report was only a first step in repairing this; the momentum it has created must not be lost in the months ahead, as more difficult issues come to be tackled by the banks, the regulator, policymakers and other authorities.