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?
Please see our response attachedQuestion 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?
Please see our response attachedQuestion 3: Paragraph 24 regarding ESG factors has been added, is it sufficiently clear?
Please see our response attachedQuestion 4: Paragraph 84 and 86 have been amended to reflect changes to CRD. Are those paragraphs sufficiently clear?
Please see our response attachedQuestion 5: Are Paragraphs 98 and 99 sufficiently clear?
Please see our response attachedQuestion 6: Point (c) of paragraph 101 has been amended to reflect the EBA’s work on dividend arbitrage schemes. Is point (c) sufficiently clear?
Please see our response attachedQuestion 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?
Please see our response attachedQuestion 8: Paragraph 126 has been added, is it sufficiently clear?
Please see our response attachedQuestion 9: Paragraph 140 has been added, is it sufficiently clear?
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201029_InternalGov_FINAL.pdf
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