Response to consultation on revised Guidelines on internal governance under CRD

Question 1: Are subject matter, scope of application, definitions and date of application appropriate and sufficiently clear?

Please see our comments in attached document.

Question 2: Are the changes made in Titles I (proportionality) and II (role of the manamgnet body and committees) appropriate and sufficiently clear?

Please see our comments in attached document.

Question 3: Are the changes made in Title III (governance framework) section 6 appropriate and sufficiently clear?

Please see our comments in attached document.

Question 4: Are the changes made in Title III section 7 (third-country branches) appropriate and sufficiently clear?

Please see our comments in attached document.

Question 5: Are the changes made in Title IV (risk culture) appropriate and sufficiently clear?

Please see our comments in attached document.

Question 6: Are the changes made in Title V (internal control framework) appropriate and sufficiently clear?

Please see our comments in attached document.

Question 7: Are the changes made in Title VI (business continuity managment) appropriate and sufficiently clear?

Please see our comments in attached document.

Upload files

Name of the organization