NBB_2022_16 – 14 June 2022 Circular – Page 1/8 boulevard de Berlaimont 14 – BE-1000 Brussels tel. +32 2 221 54 65 company number: 0203.201.340 RPM Brussels www.bnb.be Circular Brussels, 14 June 2022 Reference: NBB_2022_16 your contact:
Lisanne Vanderstappen tel. +32 2 221 41 97 lisanne.vanderstappen@nbb.be Circular to Portfolio Supervisors of Belgian Credit Institutions Issuing Belgian Covered Bonds Scope The portfolio supervisor designated in accordance with Article 16 of Annex III of the Act of 25 April 2014 on the status and supervision of credit institutions and stockbroking companies (the Banking Act).
Summary/Objectives
The Banking Act provides that Belgian credit institutions issuing Belgian covered bonds are required to designate a portfolio supervisor responsible for reporting to the National Bank on the issuing credit institution's compliance with the legal and regulatory requirements relating to such Belgian covered bonds. This circular sets out the National Bank's instructions concerning the portfolio supervisor's mission, both before and after issuance, and will enter into force on 8 July 2022. Structure
- Legal Basis
- National Bank's Instructions Concerning the Portfolio Supervisor's Mission Before Issuance of Belgian Covered Bonds
- National Bank's Instructions Concerning the Portfolio Supervisor's Mission After Issuance of Belgian Covered Bonds – Checks to Be Carried Out at Least Annually
- National Bank's Instructions Concerning the Portfolio Supervisor's Mission After Issuance of Belgian Covered Bonds – Checks to Be Carried Out at Least Monthly
- Annual Report by the Portfolio Supervisor to the National Bank
- Assessment of the Report Submitted to the National Bank by the Issuing Institution
- Specific Missions
“‘ BanqueNationaleBank DE BEGIQUE VAN BELGIE Eurosystem
Circular – Page 2/8 NBB_2022_16 – 14 June 2022 Dear Auditor, Dear Auditor, This circular includes the National Bank's instructions concerning the mission of the portfolio supervisor of Belgian credit institutions issuing Belgian covered bonds.
The portfolio supervisor is designated by the issuing credit institution, subject to the prior agreement of the National Bank. The supervisor is an auditor or an audit firm approved by the National Bank under the provisions of Article 222 of the Act of 25 April 2014 (hereinafter 'the Banking Act'). The supervisor cannot be the statutory auditor of the issuing credit institution.
The supervisor may act in the context of several issuances or issuance programmes of the credit institution. The Banking Act provides that the portfolio supervisor reports to the National Bank on the issuing credit institution's compliance with the legal and regulatory requirements relating to Belgian covered bonds.
This circular comprises seven chapters. The first explains the legal basis. The second sets out the National Bank's instructions concerning the portfolio supervisor's mission before the issuance of Belgian covered bonds. The third details the National Bank's instructions concerning the portfolio supervisor's mission after the issuance of covered bonds – checks to be carried out at least annually. The fourth contains instructions concerning the checks to be carried out at least monthly after the issuance of covered bonds. The fifth reviews the annual report by the portfolio supervisor to the National Bank. The sixth addresses the assessment of the report made by the reporting institution to the National Bank. Finally, the last chapter deals with specific missions that the National Bank may entrust to the portfolio supervisor. *
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Chapter 1: Legal Basis
Article 16, paragraph 1, of Annex III of the Act of 25 April 2014 on the status and supervision of credit institutions and stockbroking companies, as amended by the Act of 26 November 2021 aiming to transpose Directive 2019/2162 concerning the issuance of covered bonds and public supervision of covered bonds (hereinafter 'the Banking Act'), provides that the portfolio supervisor is responsible for reporting to the National Bank on the issuing institution's compliance with the legal and regulatory requirements relating to Belgian covered bonds.
Article 16, paragraphs 2 to 4, of Annex III of the Banking Act, as well as Article 11, paragraphs 4 to 7, of the Royal Decree of 11 October 2012 on the issuance of Belgian covered bonds by Belgian credit institutions, as amended by the Royal Decree of 27 January 2022 1 (hereinafter 'the RD' or 'Royal Decree'), specify the details of the portfolio supervisor's tasks and reporting obligations.
The portfolio supervisor intervenes both before and after the issuance of Belgian covered bonds.
1 The Royal Decree of 27 January 2022 amending the Royal Decree of 11 October 2012 on the issuance of Belgian covered bonds by Belgian credit institutions, the Royal Decree of 11 October 2012 on the portfolio manager in the context of the issuance of Belgian covered bonds by a Belgian credit institution, the Royal Decree of 12 November 2012 on collective investment undertakings meeting the conditions of Directive 2009/65/EC, and the Royal Decree of 25 February 2017 on certain public collective investment undertakings and their management companies, and containing various provisions.
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Chapter 2: National Bank's Instructions Concerning the Portfolio Supervisor's Mission Before Issuance of Belgian Covered Bonds
In accordance with Article 11, paragraph 4, of the Royal Decree, the portfolio supervisor is required, before the Belgian credit institution issues a Belgian covered bond, to take the necessary measures to verify that the issuing institution is able to meet the requirements concerning:
- the cover assets:
o the qualitative requirements relating to cover assets; o compliance with cover asset limits; o the requirements relating to the coverage level; o the requirements regarding the level of available liquidity and the composition of the liquidity cushion; o the requirements regarding the purchase of cover assets for a covered bond issuance;
- the register and correct recording and the segregation of assets;
- extendible maturity structures;
- the information to be provided to investors.
The qualitative requirements relating to cover assets, including derivative contracts, are described in Articles 3 and 4 of the Royal Decree and in Article 1/2 and 1/3 of Annex III of the Banking Act. The cover asset limits, the composition of the special pool, and the requirements relating to the coverage level (hereinafter 'the coverage test') are described in Article 5 of the Royal Decree and in Article 2/1 of Annex III of the Banking Act. Within the framework of the coverage test, the valuation of cover assets is important and the valuation rules are set out in Article 6 of the Royal Decree. The requirements regarding the level of available liquidity and the composition of the liquidity cushion are described in Article 7 of the Royal Decree and in Article 13 of Annex III of the Banking Act. The requirements regarding the purchase of cover assets for a covered bond issuance are described in Article 4 of Annex III of the Banking Act and the requirements relating to extendible maturity structures are detailed in Article 13/1 of Annex III of the Banking Act. The requirements relating to the information to be provided to investors are defined in Article 15/1 of Annex III of the Banking Act, as well as in Article 12 of the Royal Decree. Finally, the requirements concerning the segregation of assets and the register and correct recording are detailed in Article 9 of the Royal Decree and in Articles 5 and 15 of Annex III of the Banking Act. These provisions are commented on in Circular NBB_2022_15 on the practical implementation modalities of the Act of 25 April 2014 on the status and supervision of credit institutions and stockbroking companies, as amended by the Act of 26 November 2021 aiming to transpose Directive 2019/2162 concerning the issuance of covered bonds and public supervision of covered bonds. It is for the portfolio supervisor to determine what necessary measures should be taken. The procedures applied by the portfolio supervisor must appropriately respond to the risks, assessed by the supervisor, of significant misstatements regarding the requirements imposed by the Banking Act and the Royal Decree. The portfolio supervisor's activities must enable the establishment, with reasonable assurance, that the planned issuance of covered bonds meets the requirements imposed by the Banking Act and the Royal Decree concerning:
- the qualitative requirements relating to cover assets, including their valuation and eligibility criteria, compliance with cover asset limits, the requirements relating to the coverage level and the level of available liquidity, excess cover assets, the requirements regarding the purchase of cover assets for a covered bond issuance, and the requirements regarding derivative contracts;
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- the register and correct recording, the segregation of assets, the information to be provided to investors, and the extendible maturity structures.
The notion of 'reasonable assurance' is that used under auditing standards.
It is recalled that a credit institution must obtain authorization from the National Bank and/or the ECB before it can issue Belgian covered bonds. This prior authorization covers, on the one hand, the organizational capacity of the credit institution to issue Belgian covered bonds and to monitor them (general authorization) and, on the other hand, the extent to which a given issuance or a given issuance programme complies with the provisions of the Banking Act and the Royal Decree (specific authorization). To this end, the credit institution must submit a file to the National Bank and/or the ECB, the content of which is described in Article 80 of the Banking Act regarding the organizational capacity to issue Belgian covered bonds, as well as in Article 81 of the Banking Act regarding a given issuance or a given issuance programme. These provisions are explained in Circular NBB_2022_15 on the practical implementation modalities of the aforementioned Act. Furthermore, before granting its general authorization, the National Bank or the ECB requests the approved statutory auditor of the institution to submit a report concerning the credit institution's organizational capacity regarding its obligations arising from the Banking Act and the Royal Decree. The National Bank considers that the portfolio supervisor must, as part of its activities, review the aforementioned files compiled by the issuing credit institution and, respecting the ethical framework of auditors, the report submitted by the statutory auditor to the National Bank. Given that the objective is to obtain reasonable assurance, the National Bank considers that the portfolio supervisor must review the internal control environment regarding compliance with the requirements it is required to monitor. In the exercise of its activities, the portfolio supervisor may rely on International Standard on Assurance Engagements 3000 (ISAE 3000) (revised), Assurance Engagements Other Than Audits or Reviews of Historical Financial Information, concerning in particular the requirements for critical thinking, knowledge of legal requirements, appropriate planning of work, application of the concept of materiality (as described in auditing standards) in the context of the planning and execution of control missions, and obtaining sufficient and appropriate evidence. The portfolio supervisor submits a report to the National Bank on the results of its activities, in which it confirms that the planned issuance of covered bonds is able to meet, in all materially significant respects, the requirements imposed by the Banking Act and the Royal Decree, namely:
- the qualitative requirements relating to cover assets, including their valuation and eligibility criteria, compliance with cover asset limits, the requirements relating to the coverage level and available liquidity, excess cover assets, the requirements regarding the purchase of cover assets for a covered bond issuance, and the requirements regarding derivative contracts;
- the register and the requirement for correct recording, the segregation of assets, the information to be provided to investors, and the extendible maturity structures.
The portfolio supervisor transmits the aforementioned report to the National Bank within 45 calendar days from the date on which the National Bank indicated its agreement on the designation of the portfolio supervisor.
The issuing institution informs the portfolio supervisor no later than the day of receipt of the National Bank's agreement regarding the designation of the portfolio supervisor. The portfolio supervisor's report is subject to professional secrecy as regulated by Articles 35 and 36/13 to 36/15 of the Act of 22 February 1998 determining the organic status of the National Bank. The portfolio supervisor brings the report it submitted to the National Bank to the attention of the management of the credit institution.
Chapter 3: National Bank's Instructions Concerning the Portfolio Supervisor's Mission After Issuance of Belgian Covered Bonds – Checks to Be Carried Out at Least Annually
In accordance with Article 11, paragraph 5, first paragraph, of the Royal Decree, the portfolio supervisor is required, at least annually, to undertake reasonable steps to verify that the issuing institution meets the requirements concerning:
- the cover assets:
o the qualitative requirements relating to cover assets; o compliance with cover asset limits; o the requirements relating to the coverage level; o the requirements regarding the level of available liquidity and the composition of the liquidity cushion; o the requirements regarding the purchase of cover assets for a covered bond issuance;
- the register and correct recording, as well as the segregation of assets;
- extendible maturity structures;
- the information to be provided to investors.
Since the mission is identical to that described above in Chapter 2, the same instructions apply.
The following instructions also apply.
Regarding the reasonable steps that the portfolio supervisor must undertake, the National Bank expects the latter to test the internal control in order to collect sufficient and appropriate evidence regarding the effectiveness of the relevant internal control related to the covered bond activity. The National Bank also expects that, independently of the assessed risks of significant misstatements, the portfolio supervisor designs and implements substantive controls for operational flows and payment obligations (such as amounts repaid under amortization, interest, or recovery, adjustments made to the amount of cover assets to account for payment delays or defaults within the meaning of Article 178 of Regulation (EU) No 575/2013, etc.). To determine the frequency of this mission, the portfolio supervisor must appropriately respond to the risks, assessed by the supervisor, of significant misstatements regarding the requirements imposed by the Banking Act and the Royal Decree that it must monitor. In this regard, account is taken not only of the circumstances specific to the issuing institution (such as the availability of additional cover assets, etc.) and the covered bond issuance or issuance programme (such as the results of the coverage test, liquidity tests, and stress tests, the size of cover asset provisions, etc.), but also of market conditions (such as the evolution of the value of cover assets, etc.). The National Bank expects the portfolio supervisor to take into account, in particular, the results of its previous controls and the controls carried out at least monthly (cf. Chapter 4 below). In accordance with the Circular on the Management Report on the Assessment of Internal Control, the Management Report on the Assessment of Internal Control in Investment Services and Activities, and the Management Declaration on Periodic Prudential Reporting (Circular NBB_2011_09 of 20 December 2011), the management establishes an annual report on the assessment it carries out of internal control, including the covered bond issuance activity. The management makes the part of its report concerning the issuance of covered bonds available to the portfolio supervisor. Under the Banking Act, the approved statutory auditor of the credit institution is required to evaluate the internal control measures adopted by the institution and to transmit its findings to the National Bank. The National Bank considers that the portfolio supervisor must, as part of its activities and respecting the ethical framework of auditors, review the statutory auditor's findings regarding the issuance of covered bonds, as communicated to the National Bank. If it finds that the issuing credit institution no longer meets the requirements imposed on it by the Banking Act and/or the Royal Decree, the portfolio supervisor immediately informs the issuing credit institution and the National Bank.
Chapter 4: National Bank's Instructions Concerning the Portfolio Supervisor's Mission After Issuance of Belgian Covered Bonds – Checks to Be Carried Out at Least Monthly
In accordance with Article 11, paragraph 5, second paragraph, of the Royal Decree, the portfolio supervisor is required, at least monthly, to monitor compliance with the requirements concerning:
- coverage tests;
- the liquidity test;
- the register of cover assets.
These requirements are described in detail in Articles 5, 7, and 9 of the Royal Decree, respectively. These provisions are commented on in Circular NBB_2022_15.
The portfolio supervisor's work must be sufficient to assert with limited assurance that the covered bonds meet the requirements imposed by the Banking Act and the Royal Decree concerning:
- the qualitative requirements relating to cover assets, including their valuation, the requirements relating to the coverage level and the level of available liquidity;
- the register and the requirement for correct recording.
The notion of 'limited assurance' is that used in auditing standards. In this context, the National Bank expects the portfolio supervisor to focus its work primarily – but not necessarily exclusively – on the request for information and the performance of analytical procedures, which are sufficient to obtain, according to the professional judgment of the portfolio supervisor, limited assurance. To determine the frequency of this mission, the portfolio supervisor must appropriately respond to the risks, assessed by the supervisor, of significant misstatements regarding the requirements imposed by the Banking Act and the Royal Decree that it must monitor. This point is commented on in more detail in Chapter 3 above. In the exercise of its activities, the portfolio supervisor may rely on International Standard on Assurance Engagements 3000 (revised), on assurance engagements other than audits or reviews of historical financial information, concerning in particular the requirements for critical thinking, knowledge of legal requirements, appropriate planning of work, application of the concept of materiality (as described in auditing standards) in the context of the planning and execution of control missions, and obtaining sufficient and appropriate evidence. If it finds that the issuing credit institution does not meet the requirements imposed on it by the Banking Act and/or the Royal Decree, the portfolio supervisor immediately informs the issuing credit institution and the National Bank. This is an exception report and not a periodic report. It is therefore essential that the portfolio supervisor retains the necessary audit documentation. It must at least be able to demonstrate to which period the work was carried out (start dates
NBB_2022_16 – 14 June 2022 Circular – Page 5/8 22 February 1998 determining the organic status of the National Bank. The portfolio supervisor brings the report it submitted to the National Bank to the attention of the management of the credit institution.
Chapter 3: National Bank's Instructions Concerning the Portfolio Supervisor's Mission After Issuance of Belgian Covered Bonds – Checks to Be Carried Out at Least Annually
In accordance with Article 11, paragraph 5, first paragraph, of the Royal Decree, the portfolio supervisor is required, at least annually, to undertake reasonable steps to verify that the issuing institution meets the requirements concerning:
- the cover assets:
o the qualitative requirements relating to cover assets; o compliance with cover asset limits; o the requirements relating to the coverage level; o the requirements regarding the level of available liquidity and the composition of the liquidity cushion; o the requirements regarding the purchase of cover assets for a covered bond issuance;
- the register and correct recording, as well as the segregation of assets;
- extendible maturity structures;
- the information to be provided to investors.
Since the mission is identical to that described above in Chapter 2, the same instructions apply.
The following instructions also apply.
Regarding the reasonable steps that the portfolio supervisor must undertake, the National Bank expects the latter to test the internal control in order to collect sufficient and appropriate evidence regarding the effectiveness of the relevant internal control related to the covered bond activity. The National Bank also expects that, independently of the assessed risks of significant misstatements, the portfolio supervisor designs and implements substantive controls for operational flows and payment obligations (such as amounts repaid under amortization, interest, or recovery, adjustments made to the amount of cover assets to account for payment delays or defaults within the meaning of Article 178 of Regulation (EU) No 575/2013, etc.). To determine the frequency of this mission, the portfolio supervisor must appropriately respond to the risks, assessed by the supervisor, of significant misstatements regarding the requirements imposed by the Banking Act and the Royal Decree that it must monitor. In this regard, account is taken not only of the circumstances specific to the issuing institution (such as the availability of additional cover assets, etc.) and the covered bond issuance or issuance programme (such as the results of the coverage test, liquidity tests, and stress tests, the size of cover asset provisions, etc.), but also of market conditions (such as the evolution of the value of cover assets, etc.). The National Bank expects the portfolio supervisor to take into account, in particular, the results of its previous controls and the controls carried out at least monthly (cf. Chapter 4 below). In accordance with the Circular on the Management Report on the Assessment of Internal Control, the Management Report on the Assessment of Internal Control in Investment Services and Activities, and the Management Declaration on Periodic Prudential Reporting (Circular NBB_2011_09 of 20 December 2011), the management establishes an annual report on the assessment it carries out of internal control, including the covered bond issuance activity. The management makes the part of its report concerning the issuance of covered bonds available to the portfolio supervisor. Under the Banking Act, the approved statutory auditor of the credit institution is required to evaluate the internal control measures adopted by the institution and to transmit its findings to the National Bank. The National Bank considers that the portfolio supervisor must, as part of its activities and respecting the ethical framework of auditors, review the statutory auditor's findings regarding the issuance of covered bonds, as communicated to the National Bank. If it finds that the issuing credit institution no longer meets the requirements imposed on it by the Banking Act and/or the Royal Decree, the portfolio supervisor immediately informs the issuing credit institution and the National Bank.
Chapter 4: National Bank's Instructions Concerning the Portfolio Supervisor's Mission After Issuance of Belgian Covered Bonds – Checks to Be Carried Out at Least Monthly
In accordance with Article 11, paragraph 5, second paragraph, of the Royal Decree, the portfolio supervisor is required, at least monthly, to monitor compliance with the requirements concerning:
- coverage tests;
- the liquidity test;
- the register of cover assets.
These requirements are described in detail in Articles 5, 7, and 9 of the Royal Decree, respectively. These provisions are commented on in Circular NBB_2022_15.
The portfolio supervisor's work must be sufficient to assert with limited assurance that the covered bonds meet the requirements imposed by the Banking Act and the Royal Decree concerning:
- the qualitative requirements relating to cover assets, including their valuation, the requirements relating to the coverage level and the level of available liquidity;
- the register and the requirement for correct recording.
The notion of 'limited assurance' is that used in auditing standards. In this context, the National Bank expects the portfolio supervisor to focus its work primarily – but not necessarily exclusively – on the request for information and the performance of analytical procedures, which are sufficient to obtain, according to the professional judgment of the portfolio supervisor, limited assurance. To determine the frequency of this mission, the portfolio supervisor must appropriately respond to the risks, assessed by the supervisor, of significant misstatements regarding the requirements imposed by the Banking Act and the Royal Decree that it must monitor. This point is commented on in more detail in Chapter 3 above. In the exercise of its activities, the portfolio supervisor may rely on International Standard on Assurance Engagements 3000 (revised), on assurance engagements other than audits or reviews of historical financial information, concerning in particular the requirements for critical thinking, knowledge of legal requirements, appropriate planning of work, application of the concept of materiality (as described in auditing standards) in the context of the planning and execution of control missions, and obtaining sufficient and appropriate evidence. If it finds that the issuing credit institution does not meet the requirements imposed on it by the Banking Act and/or the Royal Decree, the portfolio supervisor immediately informs the issuing credit institution and the National Bank. This is an exception report and not a periodic report. It is therefore essential that the portfolio supervisor retains the necessary audit documentation. It must at least be able to demonstrate to which period the work was carried out (start dates
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and end), what work was carried out, what evidence was obtained (findings), and what communications, if any, were addressed to the issuing institution and to the Bank.
Chapter 5: Annual Report of the Portfolio Supervisor to the Bank
As provided for in Article 11, paragraph 7, of the Royal Decree, the portfolio supervisor transmits to the Bank, at the end of the issuing credit institution's fiscal year, a report on the results of its work in which it confirms that the covered bond issuance meets, in all materially significant respects, the requirements imposed by the Banking Act and the Royal Decree concerning:
- qualitative requirements regarding coverage assets, including their valuation and eligibility criteria, compliance with coverage asset limits, requirements regarding coverage levels and available liquidity levels, excess coverage assets, requirements regarding the purchase of assets covering a covered bond issuance, and requirements regarding derivative contracts;
- the register and the requirement for correct registration, the segregation of assets, the information to be provided to investors, and extendible maturity structures.
The portfolio supervisor transmits the aforementioned report to the Bank within 60 days following the close of the fiscal year. This communication is subject to professional secrecy as regulated by Articles 35 and 36/13 to 36/15 of the Law of 22 February 1998 establishing the organic statute of the Bank. The portfolio supervisor brings the report it has transmitted to the Bank to the attention of the management of the credit institution. The said report may include a reservation regarding the use that may be made of it by senior management.
The Bank considers it essential that the portfolio supervisor retains the necessary audit documentation. It must at least be able to demonstrate to which period the work was carried out (start and end dates), what work was conducted, what evidence was obtained (findings), and what communications, if any, were addressed to the issuing institution and to the Bank.
Chapter 6: Assessment of the Report Addressed to the Bank by the Issuing Institution
Pursuant to Article 15, paragraphs 1st, 4°, and 2, of Annex III of the Banking Act, the issuing institution is required to transmit to the Bank quarterly a report prepared according to the scheme defined by the latter. This scheme and comments are found in Annexes 3 and 4 of Circular NBB_2022_15 regarding reporting.
The Bank expects the portfolio supervisor to transmit to it the results of an assurance mission regarding the aforementioned reporting at the end of the issuing institution's fiscal year. In the said report, the portfolio supervisor confirms that the end-of-year reporting was drafted in all materially significant respects applying the legal provisions and the Bank's instructions. Furthermore, the portfolio supervisor confirms that the issuing institution's end-of-year report is, in all materially significant respects and to the extent that the data derives from it, consistent with the issuing institution's accounting and the register referred to in Article 9 of the Royal Decree, in that it is complete, i.e., it mentions all data appearing in the accounting and the register on the basis of which it is established, and that it is correct, i.e., it corresponds exactly with the accounting and the register on the basis of which the report is established. The data declared in the CB11 section: "monitoring of emission limit criteria" of Annex 4 of Circular NBB_2022_15, do not fall within the scope of the portfolio supervisor's assurance mission.
In the context of the aforementioned mission, the Bank expects the portfolio supervisor to request that the senior management of the issuing credit institution confirm that the end-of-year reporting is, in all materially significant respects, consistent with the issuing institution's accounting and the register referred to in Article 9 of the Royal Decree, in that it is complete, i.e., it
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mentions all data appearing in the accounting and the register on the basis of which the report is established, and that it is correct, i.e., it corresponds exactly with the accounting and the register on the basis of which the report is established, and that the end-of-year report was drafted applying the legal provisions and the Bank's instructions.
In the exercise of its activities, the portfolio supervisor may rely on International Standard on Assurance Engagements 3000 (revised), on assurance engagements other than audits or reviews of historical financial information, concerning in particular the requirements regarding critical thinking, knowledge of legal requirements, appropriate planning of work, application of the concept of materiality (as described in auditing standards) in the context of the planning and execution of control missions, and obtaining sufficient and appropriate evidence.
The portfolio supervisor transmits the report to the Bank within 60 days following the close of the fiscal year.
Chapter 7: Specific Missions
The Bank may charge the portfolio supervisor with specific missions. It proceeds in writing, with a copy to the concerned institution. The letter by which the Bank charges the portfolio supervisor with one or more specific missions includes at least the following points:
- the subject of the mission;
- the scope of the mission, with reference to applicable legislation as well as the regulation and circulars of the NBB;
- the form of the report;
- the deadline by which the report must be transmitted to the Bank.
Before charging the portfolio supervisor in writing with a specific mission, the Bank contacts him and discusses the appropriate formulation.
Please accept, Madam Auditor, Sir Auditor, the assurance of my distinguished consideration.
Pierre Wunsch
Governor