4.2.3 Module: Internal Control
Item 12 - Compliance Work Plan
63. Under the 2015 Guidelines, ESMA receives CRAs’ compliance work plans on a semi-annual basis, in addition to whenever they are updated. This information is useful for ESMA to understand where CRAs are directing their compliance resources. However, ESMA believes that a semi-annual frequency of submission may not be appropriate for this document which is typically not updated on a semi-annual basis.
64. To address this issue ESMA is clarifying that "category 1" CRAs should submit this document on an annual basis, whereas "category 2" CRAs can submit this document on a bi-annual basis.
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Text of proposed guidelines |
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Item 12 - Compliance Work Plan CRAs should submit a copy of their Compliance Work Plan to ESMA.
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Q13. Do you agree with the proposed approach regarding the submission of the Compliance Work programme? If not please explain.
Item 13 - Internal Audit Work Plan