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ecoDa - The European Confederation of Directors' Association

The scope is clear, we understand that now investment firms are subject to the guidelines. It might however be difficult for investment firms to comply with the new guidelines in a short period of time especially in Member States where the local regulations on corporate governance did not apply to them.
For ecoDa, it’s not clear why the guidelines add a section on AML/CFT and at the same time mention the EBA is developing a separate work on AML. If AML will be covered in a separate document, why is it included here? FYI, the Luxembourg regulator is currently reviewed the local regulation on internal governance and is removing AML and outsourcing from it because it will be covered in separate regulations
Same comment as point 2: why including a part on ESG if it will be covered in another document?
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Paragraphs 98 and 99 give high level guidelines on non-discrimination of staff and egal opportunities for all genders but it might be too high level and most credit institutions will struggle with the concrete implementation of this high level principles
The point on dividend arbitrage schemes is linked with AML/CTF and ecoDa doesn’t see why there is a separate paragraph on this point.
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ecoDa - The European Confederation of Directors' Association