Response to consultation on Regulatory Technical Standards to specify the minimum content of the suitability questionnaire, curriculum vitae and internal suitability assessment
Question 1: Are the draft RTS appropriate and sufficiently clear?
Article 2 RTS – Suitability Forms: Febelfin seeks clarification as to whether Article 2 implies that a new suitability form will be introduced by the competent authorities.
Article 4(2) RTS – Assessment of knowledge, skills and experience: This article is not aligned with Section 10, para 108 of the draft EBA GL that provides that a member of the management body should fulfil all knowledge and skill elements as set out in Section 6 not later than one year after taking up the position and not six months as provided in the RTS .
Article 5 RTS – Practical Burden: We consider the process described in Article 5 RTS to be cumbersome for both candidates and entities in scope, in particular from a follow-up and administrative burden perspective. This should be simplified.
Article 10 (2) (g) RTS – Information to be included in the suitability questionnaire: What is the justification for the emphasis on banking experience given that not only credit institutions are in scope?