117. In accordance with Article 109(2) and (3) of Directive 2013/36/EU, the consolidating CRD- institution should ensure that a group-wide policy for the assessment of suitability of all members of the management body and key function holders is implemented consistently and well integrated in all subsidiaries within the scope of prudential consolidation, including those not subject to Directive 2013/36/EU, even when they are established in offshore financial centers.
118. The policy should be adjusted to the specific situation of the credit institutions that are part of the group and subsidiaries within the scope of prudential consolidation that are not themselves subject to Directive 2013/36/EU. Competent bodies or functions within the consolidating CRD-institution and its subsidiaries should interact and exchange information for the assessment of suitability as appropriate.
119. The consolidating CRD-institution should ensure that the suitability assessment complies with all specific
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