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Change in position
Published: 02 March 2021
As part of our remit we assess prospective management and supervisory board members for fitness for their position. Such an assessment of fitness is linked to the position for which the person is considered and we conduct it prior to the appointment. This also applies when a previously assessed management or supervisory board member is given a different position or remit within the same company. A change of position constitutes an assessment time as referred to in part 1.5.a of the Policy Rule on Fitness 2012.
Institutions are expected to notify us beforehand in the case of changes in the division of duties between policymakers. Subsequently, we determine whether the candidate must be assessed for fitness for the new position. As a rule, this is the case if the new position entails an increase in duties and responsibilities, as this means a significant change in the requirements for fitness. You can submit the assessment application using the Change in Position or Remit Form via Supervisory applications in My DNB.
Below are some examples of changes in position for which we assess fitness. When in doubt or if you have any questions, please send an email to our Expert Centre on Fit & Proper Assessments at email@example.com.
Examples of changes in position for which DNB assesses fitness
The examples below relate to frequently occurring changes in position. For supervised institutions that are not mentioned below, such changes in position may also require assessment.
Banks and insurers
- A member of the supervisory board is nominated as chair of the supervisory board.
- A member of the supervisory board is nominated as chair of the risk committee.
- A redistribution of responsibilities of the board, in which a board member is for instance given additional tasks and duties following a (temporary) vacancy in the board.
Pension funds and premium pension institutions (PPIs)
- An incumbent management or supervisory board member is nominated as chair of the management board or supervisory board.
- An incumbent management board member is nominated as key function holder.
- An incumbent management board member is nominated as member of the investment (advisory) committee or is to become responsible for investments.
- An incumbent management board member or member of the investment (advisory) committee is nominated as chair of the investment (advisory) committee.
Crypto service providers
- A member of the management or supervisory board is nominated as chair.
- Portfolio changes, in which responsibility for compliance with the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en financieren van terrorisme – Wwft) is taken on by a different board member.
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