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Continuous notification requirement for antecedents
Published: 01 February 2023
De Nederlandsche Bank (DNB) assesses incumbent and prospective policymakers, such as management and supervisory board members, for fitness to fulfil their duties and whether their propriety is beyond doubt. In conducting our assessments, we also take any antecedents into account. Even after a policymaker takes office, antecedents relevant to their fitness and/or propriety may arise. This news item is a reminder of the obligation to report new antecedents immediately after an assessment.
What are antecedents?
Our Open Book on Supervision provides extensive clarification on what we mean by antecedents: Antecedents (dnb.nl).
A continuous notification requirement applies to antecedents. What does this mean?
Fitness and propriety requirements apply to policymakers on an ongoing basis. This means that supervised institutions and the relevant policymakers are obliged to immediately report to DNB any new antecedents that arise after our initial assessment has been completed. We will then evaluate whether the antecedent is a reason to doubt the fitness and/or propriety of the policymaker in question and thus a reason to conduct a reassessment. This is by no means always the case.
If you are in doubt as to whether an event qualifies as an antecedent, apply the rule of thumb that it is better to report too much than too little. When investigating a reported antecedent, we regard full disclosure as a mitigating factor.
Any supervisory measures we have imposed will be known to us. You do not need to report these. However, you are required to report any other formal or informal measures imposed by another supervisory authority, such as the AFM, the ECB, or a foreign supervisory authority.
If you wish to report an antecedent or have any questions, please contact the Expert Centre on Fit & Proper Assessments at firstname.lastname@example.org.
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