The Banking Executive Accountability Regime (BEAR) formally came into effect on 1 July 2018 for the largest banks, and other ADIs have until mid-next year to get themselves ready. They had better start early, based on the Big Four's experience, warned APRA chairman Wayne Byres.Byres told the Annual Risk Management Association CRO Conference in Sydney yesterday that "all up, 85 individuals across the four banks have been registered - the directors and senior executive team, plus a few others" at the largest ADIs now operating under the BEAR."The major banks have identified and registered their accountable persons, developed reasonably detailed accountability statements, and from these put together accountability maps for their organisations. Clarifying that accountability has been valuable in itself. "Having got the system operational, however, we do not regard the job as done. For a start, we will need to see how well the allocated responsibilities work in practice, and we are quite open to revisiting these as we learn from experience," Byres said.However, the new rules would not necessarily aid the industry to regain the community's trust, at least directly, he said. "Where I hope the BEAR will have a positive impact - albeit indirectly, and over time - is through forcing the industry to hold itself to account much more firmly and quickly than has been the case to date," Byres said."This appears to have been the case in other jurisdictions that have introduced BEAR-style regimes, and I certainly hope that we will see a similar impact here."One of the BEAR components is remuneration, with rules that come fully into effect during the course of 2019. The BEAR requires ADIs to defer a minimum proportion of an accountable person's variable remuneration - generally 40 per cent for executives and 60 per cent for the CEO of a large bank - for a minimum of four years.It also requires ADIs to have remuneration policies that provide for the reduction in variable remuneration should an accountable person fail to comply with their obligations, and - importantly - to exercise the provision should circumstances warrant it. Byres flagged three key areas in which improvement for the BEAR is needed:•    outcomes - multiple examples where employees at lower levels received downward adjustments to their remuneration, but these were not always matched by corresponding adjustments at an executive level to recognise overall line or functional accountability, which he said must change;•    metrics - should be part of any performance assessment, although excessive weightings can drive behaviours that don't support the long-term success of the company; and•    oversight - shortcomings at the Board remuneration committee level of remuneration practices and framework made it clear that stronger governance of executive remuneration is needed, and for this a more structured and systemic contribution from the risk functions within banks will be needed.