Initial assessment – reputation assessment

We conduct a reputation assessment if a natural person acquires or increases a qualifying holding in a financial enterprise which requires us to issue a declaration of no-objection (DNO). This involves assessing the track record of the day-to-day policymakers of the legal entity requesting the DNO.

From 1 July 2023, under the Act amending the Financial Markets Act (Wijzigingswet financiële markten 2022), holders of a DNO will be subject to an ongoing reputation requirement. This means that as of that date, reputation assessments will also be required after the DNO has been granted. From 1 July 2023, new policymakers at holders of a qualifying holding will be subject to a reputation assessment, which not only evaluates their integrity but also their professional competence.

Assessment

We perform reputation assessments based on the information provided by the natural person to be assessed, and our evaluation of that information. A reputation assessment not only involves an evaluation of a person's integrity and propriety, but also of their professional competence. In assessing competence, we distinguish between management competence and technical competence.

Professional competence

Management competence largely depends on experience in acquiring and managing holdings, and the individual's conscientiousness in the process. Technical competence is mostly evident through experience in leading a financial enterprise as a majority shareholder or as someone who has effectively managed a financial enterprise. The experience must also attest to the exercise of due care.
Contrary to integrity assessments, assessments of professional competence also take into account the level of influence of the DNO applicant in the financial enterprise.

European regulations

The reputation assessment is based on European regulations aimed at harmonising the assessment of acquisitions and increases of qualifying holdings in the financial sector.