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Intrum AB

The Institute of Internal Auditors (IIA) has done a major update of the Three lines of Defense Model this summer and the model is not called anymore “Three lines of defense” but “Three lines model”. Additionally , the model now advocates that 1st and 2nd line can be blended. This is quite a substantial difference compared to EBA Guidelines on Internal Governance which clearly requires the independence of the control functions in credit institutions. How will you intend to take the IIA Three lines model into consideration in the consultation to revise the Guidelines on internal governance? Will this impact the thikning around three lines including renaming them from three lines of defense to just three lines? It would be somewhat challening to have two approaches which are somewhat deviating form each other.
Intrum AB