Response to eBA launches consultation to revise its Guidelines on internal governance

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

Definition of prudential consolidation is different between these guidelines and the guidelines on the assessment of the suitability of members.

Question 2: Point (d) has been added, throughout the Guidelines references to money laundering and terrorism financing and the institutions obligations have been added, are those references sufficiently clear?

Proportionality principles differ between the two guidelines as above.

Question 3: Paragraph 24 regarding ESG factors has been added, is it sufficiently clear?

Para 24: Are social and environmental risks in reference to the institution’s P&L and business or in reference to what risk are caused by the institution on the environment and the planet in general?

Question 4: Paragraph 84 and 86 have been amended to reflect changes to CRD. Are those paragraphs sufficiently clear?

Yes, clear.

Question 5: Are Paragraphs 98 and 99 sufficiently clear?

Para 92: What is a righteous culture?

Question 6: Point (c) of paragraph 101 has been amended to reflect the EBA’s work on dividend arbitrage schemes. Is point (c) sufficiently clear?

Yes, clear.

Question 7: Section 11 has been added to provide guidelines on loans and transactions with members of the management body and their related parties, reflecting changes to CRD. Is the section appropriate and sufficiently clear?

Yes, clear.

Question 8: Paragraph 126 has been added, is it sufficiently clear?

Yes, clear.

Question 9: Paragraph 140 has been added, is it sufficiently clear?

Yes, clear.
Para 166: Is AML/TF to be a separate control function?

Name of the organization

Bank of Cyprus Public Company Limited