4.2.6 Module: Internal Policies and Procedures
Item 23 - Active Internal Policies and Procedures **New**
92. Under the 2015 Guidelines, there is no requirement for CRAs to submit a full list of all valid internal policies and procedures. This information is important to enable ESMA to track any changes in the internal control environment, policies regarding rating activities, endorsement or guidance and instruction provided to staff.
93. To address this issue, under the proposed Guidelines ESMA is introducing a standalone requirement for CRAs to provide this information through a standardised template. This will ensure that ESMA is kept up to date on all CRAs active internal policies and procedures, reducing the need for bilateral or ad-hoc requests for information.
94. Given that the purpose of this Template is to ensure ESMA is kept up to date with any changes it is proposed that this template be submitted on an annual basis by both categories of CRA, as well as on an "as soon as" basis should any changes be made. This will ensure that ESMA does not need to require this information on a bilateral or ad-hoc basis.
|
Text of proposed guidelines |
|---|
|
Item 23 - Active Internal Policies and Procedures CRAs should submit Template 13 [Policies and Procedures] in order to provide ESMA with an overview of all active internal policies and procedures. In case of changes to existing policies and procedures, the CRA is required to flag such change, explain the rationale and attached the revised version of the document including amendments in track changes. |