EBA published guidelines on 6 January 2012 on the process that institutions should adhere to when extending or changing the advanced approach of operational risk (AMA). The purpose of these AMA change guidelines is to achieve a harmonised process, which eases communications and coordination with the host supervisors and helps to inform DNB on time about AMA changes.
On 6 March 2012, DNB included these EBA guidelines in full in Section 17 of the Beleidsregel toepassing richtsnoeren EBA Wft [Policy Rule on the Application of EBA Guidelines]. This policy rule refers to the English language edition of the EBA guidelines.
Substance of the guidelines
The guidelines stipulate among other things
- that institutions should implement internal policies for possible AMA extensions and changes, including appropriate criteria for the classification of these extensions and changes into four categories: extensions; significant changes; major changes, and minor changes. Whereas extensions and significant changes require prior permission from DNB, major and minor changes should be reported to DNB and DNB may convey its concerns about or demand improvements to the proposed changes;
- that institutions should submit their internal policies for AMA extensions and changes (and possible future changes to these policies) to DNB (by 30 June 2012 at the latest, see EBA-guidelines art). 5 and art. 9);
- that DNB is deemed to assess the institutions’ internal policies with respect to AMA changes;
- approval, documentation, implementation, internal/external independent review of internal policies by the institution.