In what may be the newest wrinkle in troubles for money-losing financial firms, boards may be singled out for poor oversight. Union pension adviser CtW Investment Group is going after Citigroup (NYSE: C), declaring "Accountability for risk management begins with the Audit Committee, and they will be the first to face an opposition shareholder vote," according to Reuters. The group may fight the re-election of some directors at the bank's next annual meeting.

The point may be well taken. A look that the charter for the audit committee at Citi shows that it does say the group is responsible for overseeing risk management activity by the bank's management. The question becomes to what extent does that entail digging into the bank's balance sheet and specific investment decisions. The audit committee almost certainly could have done more to question the company's move into subprime instruments but may have felt that such a move would be too intrusive.

The next question will be if any members of the board are liable for their actions. The group may defend itself by interpreting the issue of looking at risk decisions in very broad terms. But Citi's subprime mess did turn out to be a very broad problem.

Douglas A. McIntyre is an editor at 247wallst.com.