Regulatory Alerts2016-03-04
Added · Updated
Second-tier senior officers: suitability requirements
Banks and insurers must determine whether their second-tier senior officers are suited to their positions by assessing sufficient knowledge, skills, and professional behavior. Institutions are required to draft a suitability assessment for all screened managers, which should not exceed one page and must demonstrate alignment with the job profile and the institution's situation. While the assessment does not need to be submitted to the DNB, the regulator may review the institution's process setup or perform sample tests and, in some cases, conduct its own suitability screening. This policy statement remains applicable until the introduction of Article 91a of CRD6 replaces the concept with 'key function holder' in mid-2026.
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