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					Cross-Sectoral Issues on Internal Governance
                 Ana Moitinho Byrne
           (Instituto de Seguros de Portugal)

                   Malta, 09/04/2010




                                                Page 1
                                                                  CEIOPS


Index


       3L3 Task Force on Internal Governance


       Cross-sectoral stock-take on internal governance issues


       Main findings


       Next steps




9 April 2010                                                      Page 2
                                                                                CEIOPS


 3L3 Task Force on Internal Governance

• The “3L3 Task Force on Internal Governance” (TFIG)
    – Created according to the 3L3 Committees “Medium Term Work
      Programme” for 2008-2010
        • Internal governance was one of the 6 priority areas identified for joint
          cross-sector work
    – Composed of experts from the banking, insurance and securities
      markets supervisors, members of the three Level 3 committees
      (CEIOPS, CEBS and CESR)




9 April 2010                                                                    Page 3
                                                                        CEIOPS


 3L3 Task Force on Internal Governance

• Mandate
    – Identify consequences of differences in internal
      governance requirements in sectoral legislation     Work developed
      (both Level 1 and Level 2) which have               between
      significant    practical  consequences       for    September 2008 and
                                                          December 2009
      institutions, and making recommendations for
      Level 3 measures to enhance convergence
    – Developing cross-sector guidance for institutions
      and conglomerates operating in different            Scope (and timing)
      financial sectors in the area of internal           yet to be defined
      governance, within the current legal framework




9 April 2010                                                            Page 4
                                                                                                   CEIOPS


 3L3 Task Force on Internal Governance

• Deliverables
    – Preliminary report in December 2008
    – Final report
        • “Cross-sectoral           stock-take      and    analysis     of   internal    governance
          requirements”
               (http://www.ceiops.eu/media/files/consultations/3L3-call-for-evidence-internal-
               governance/3L3-cross-sectoral-stock-take-and-analysis-internal-governance-v2.pdf)

        • Under “Call for Evidence” until... today!
               (http://www.ceiops.eu/media/files/consultations/3L3-call-for-evidence-internal-
               governance/3L3-Call-for-evidence-internal-governance.pdf)

                      This report will be the basis for this presentation.
           However, some adaptations were made to align the analyses made with
                the final advice from CEIOPS to the European Commission.

9 April 2010                                                                                       Page 5
                                                                  CEIOPS




       3L3 Task Force on Internal Governance


       Cross-sectoral stock-take on internal governance issues


       Main findings


       Next steps




9 April 2010                                                      Page 6
                                                                                                   CEIOPS


 Cross-sectoral stock-take on internal
  governance issues
• Scope of the stock-take
    – Internal governance provisions applicable to entities in the
      areas of banking, insurance and securities
        • Includes binding (Level 1 and Level 2) and non-binding (Level 3)
          provisions

                   Issues out of scope                                 Reason

         Undertakings for Collective Investment in
                                                     Under revision
         Transferable Securities directive (UCITS)

         Financial Conglomerates Directive (FCD)     Under revision
                                                     Subject of a separate review by another 3L3
         “Fit and proper” requirements
                                                     group
                                                     Subject of review by the EU Commission, a
         Remuneration issues                         number of national supervisors, and by CEBS
                                                     and CEIOPS

9 April 2010                                                                                       Page 7
                                                       CEIOPS


 Cross-sectoral stock-take on internal
  governance issues
• Material considered




                        Level 1 directive
                        Level 2 directive/regulation
                        Level 3 guidance


9 April 2010                                           Page 8
                                                                            CEIOPS


 Cross-sectoral stock-take on internal
  governance issues
• Material considered
    – Assumptions
        • Although the CRD and the CAD do not follow the Lamfalussy
          legislative architecture, they were compared to Level 1 requirements
        • The annexes of the CRD were considered to be comparable to Level 2
          requirements




9 April 2010                                                                Page 9
                                                                                                    CEIOPS


 Cross-sectoral stock-take on internal
  governance issues
• Material considered
    – Interconnections between directives
        • Article 34 of the CAD applies Article 22 of the CRD and respective
          Level 3 measures to every investment firm that is not an exempt CAD
          firm
        • Article 1(2) of MiFID applies the organisational requirements in its
          Article 13 (and in the Level 2 implementing directive) to credit
          institutions that carry on one or more investment services or
          activities

   Conclusion: every investment firm that is not an exempt CAD firm is subject to both MiFID and
  CAD/CRD governance requirements. Consequently, many banks are subject to both MiFID and
  CRD organisational requirements (at least in relation to the conduct of their securities business).
  But the purpose of the stock-take was to compare the requirements for each activity on a
                                        standalone basis.

9 April 2010                                                                                       Page 10
                                                                             CEIOPS


 Cross-sectoral stock-take on internal
  governance issues
• Options to proceed
    – Challenge
        • Maintain an appropriate balance between delivering harmonised
          standards, while maintaining justifiable sectoral differences
        • Consider carefully the means of delivering effective harmonisation if
          that is “desirable”
    – Available possibilities
        • Legislation – amendment of Level 1 directives and/or Level 2
          directives or regulations where relevant, including the Level 2
          implementing measures for Solvency II
        • Guidance – production or amendment of Level 3 guidance either by
          individual committees (CEBS, CEIOPS and CESR) or by the 3L3
          committees together

9 April 2010                                                                Page 11
                                                                       CEIOPS


 Cross-sectoral stock-take on internal
  governance issues
• Options to proceed
    – “Desirable degree of harmonisation”
        • The rating was attributed according to the following scale




9 April 2010                                                           Page 12
                                                                      CEIOPS


 Cross-sectoral stock-take on internal
  governance issues
• Approach adopted – “building block approach”

                     System of internal governance

          Corporate structure and organisation
               (including management body)



               Risk management system                    Group
                                                     structures and
                                                     group specific
                 Internal control system                 issues



        Supervisory review, internal reporting and
                    public disclosure
                                                                      Page 13
                                                                  CEIOPS




       3L3 Task Force on Internal Governance


       Cross-sectoral stock-take on internal governance issues


       Main findings


       Next steps




9 April 2010                                                      Page 14
                                                                                                                         CEIOPS


                     Main findings
                             Corporate structure and organisation

  Area                                             Main findings                          DDH *             Rationale

                             • Banking: obligation to ensure that areas of                         • Issues are essentially
responsibility and




                               responsibility and authority are sufficiently clear and               covered in the three
  accountability




                               transparent for any reporting lines that deviate from                 sectors
     Lines of




                               the entity's legal structure                                        • Lines of responsibility
                                                                                           Low       and accountability
                             • Banking and insurance: requirement to have an
                                                                                                     depend more on the
                               organisational structure with appropriate segregation
                                                                                                     characteristics of the
                               of responsibilities or duties
                                                                                                     entity than on the
                             • Securities: prevention of conflicts of interest                       sectoral specificities
                             • Banking and insurance: adequate or appropriate
                               “segregation of duties” or “segregation of                          • An effective
     Conflicts of interest




                               responsibilities”                                                     management of conflicts
                             • Securities:                                                           is a key element of any
                                MiFID explicitly states that an entity should put in                internal governance
                                 place “effective organisational and administrative       Medium     system, both to protect
                                 arrangements with a view to taking all reasonable                   the interests of an
                                 steps designed to prevent conflicts of interest”                    entity’s clients and to
                                MiFID requires entities to set out in a written policy              maintain market
                                 the main conflicts they face and the measures                       confidence
                                 adopted to manage them

                    9 April 2010                    * DDH = Desirable degree of harmonisation                            Page 15
                                                                                                                        CEIOPS


                Main findings
                             Corporate structure and organisation

Area                                              Main findings                            DDH             Rationale
                             • For simplification, in the report this term encompasses             • A similar provision as
Tasks and responsibilities
of the management body




                               both the management and the supervisory functions                     that of Article 40 of
                             • Banking: stress of the “ensuring a strategy” and                      Solvency II could be
                               “know-your-structure” requirements                                    introduced to the L1 text
                             • Banking and securities: requirements are similar in                   for the other two sectors
                               content, but vary from being addressed to the entities     Medium   • The “know–your-
                               themselves or to the management body                                  structure” principle and
                             • Insurance: Article 40 of Solvency II makes it clear that              the risk-alignment
                               the management body of an undertaking is ultimately                   objective of Basel II
                               responsible for compliance with internal governance                   should also be taken into
                               requirements                                                          account
data quality aspects




                             • Banking: a visible emphasis is put on large exposures
Record keeping and




                               records                                                             • L3 guidance for the
                                                                                                     banking sector could be
                             • Insurance: implementation of suitable processes and
                                                                                                     adopted regarding the
                               procedures to ensure the reliability, sufficiency and
                                                                                          Medium     maintenance of orderly
                               adequacy of both the statistical and accounting data
                                                                                                     records of the business
                             • Securities: keeping records of all services and                       and the internal
                               transactions undertaken and set a business continuity                 organisation
                               policy concerning data

               9 April 2010                                                                                             Page 16
                                                                                                                CEIOPS


              Main findings
                         Corporate structure and organisation

Area                                          Main findings                        DDH            Rationale
                         • Banking: CRD stresses the concept of own funds to
Accounting systems and




                           cover banking risk and that these should be properly
                           registered in the internal accounting records                 • The general provision
                                                                                           stated in each sectoral
     procedures




                         • Insurance: Solvency II includes this provision in the
                                                                                           directive is similar and is
                           context of the implementation of an internal control
                                                                                   Low     set in the context of
                           system
                                                                                           high-level requirements
                         • Securities: MiFID (L2) provides further detail on the           regarding governance
                           accounting policies and procedures that should be               arrangements
                           established that enable investment firms to deliver
                           financial reports in a timely manner
                         • Banking: the banking business must be effectively
                           directed by at least two persons of sufficient good           • As a consequence of the
                           repute and experience – no exceptions are allowed
composition




                                                                                           TFIG’s work, the CEIOPS’
“Four eyes”




                         • Insurance: no explicit “four eyes” requirement                  advice to the
                         • Securities: same requirement as banking applies,        Low     Commission on L2
                           although a securities entity may be a sole trader               implementing measures
                           provided it has alternative arrangements in place               included a “four eyes”
                           which ensure sound and prudent management of the                requirement
                           entity

             9 April 2010                                                                                      Page 17
                                                                                                                        CEIOPS


               Main findings
                           Corporate structure and organisation

   Area                                         Main findings                            DDH              Rationale
                           • Banking: L3 guidance for banks let these consider                   • “Public-interest entities”
their terms of reference
  subcommittees and




                             what committee structure is appropriate, if this                      are obliged to have an
    Committees and




                             facilitates the development and maintenance of good                   audit committee cf.
                             governance practices                                                  Article 41 of Directive
                           • Insurance:                                                            2006/43/EC
                                                                                         Low
                              The management body should consider whether a                     • Some types of
                               committee structure is appropriate in the context of                committees are sector-
                               the system of governance (“white text” of CP 33)                    specific
                              Committee for the revision of the internal model, for             • Other situations could be
                               undertakings that have one                                          covered by L3 guidance
                                                                                                 • Harmonisation could be
                           • Banking: notification requirement in L3 guidance                      achieved by:
                           • Insurance: Solvency II requires that entities give prior               extending the
                             notice when outsourcing material activities                             notification requirements
       Outsourcing




                           • Securities:                                                             to all sectors
                                                                                        Medium      include in all cases a
                             – Notification is only required under certain conditions
                                                                                                     requirement for the
                               laid down in MiFID (L2) related to service providers
                                                                                                     availability on request to
                               located in third countries                                            the supervisory authority
                             – MiFID (L2) includes a list of exclusions for the                      of all relevant
                               concept of outsourcing                                                information on
                                                                                                     outsourced activities
                                             CEIOPS


 Main findings
      Corporate structure and organisation




9 April 2010                                 Page 19
                                                                                                                CEIOPS


            Main findings
                    Risk management system

  Area                                    Main findings                            DDH             Rationale
a risk management
Implementation of




                    • Banking and securities: the risk management system                   • The provisions for
                      is explicitly embedded in the internal control activities              implementing a risk
                                                                                             management system are
       system




                    • Insurance:
                                                                                   Low       broadly similar for the
                       Solvency II describes this as a system per se                        three sectors – at least
                       Solvency II has more detail at L1 than either of the                 the outcome is almost
                         other two directives                                                the same


                                                                                           • There are gaps and/or
  Risk management




                    • Banking: no mandatory general requirement to set a                     inconsistencies in the
                      risk management function (only under sector-specific                   directives such as
       function




                      circumstances)                                                         whether and how the risk
                                                                                  Medium     management function
                    • Insurance and securities: establishment of a risk
                                                                                             should be independent
                      management function where this is proportionate
                                                                                             from and/or interact with
                    • “Risk management function” vs. “risk control function”                 the other functions and
                                                                                             their respective tasks




           9 April 2010                                                                                        Page 20
                                                                                                                    CEIOPS


               Main findings
                         Risk management system

  Area                                        Main findings                           DDH             Rationale
                                                                                              • Where the same risk is
Risks covered by the




                         • Banking: no explanation of which risks or risk types                 covered explicitly by
 risk management




                           have to be covered                                                   different directives (e.g.
                         • Insurance: states explicitly that the risk management                operational risk), there
       system




                           system should cover the risks that are included in the               may be grounds for
                                                                                     Medium
                           calculation of the SCR                                               harmonisation at L3 as to
                         • Securities: MiFID has no risk specific material, except              what the relevant
                           for the general requirement to have “effective                       policies, processes and
                           procedures for risk assessment”                                      procedures might be for
                                                                                                those risks
   Risk assessment and




                         • Banking: specific L3 guidance exists dealing with the
                           issue of stress tests, subject to the principle of                 • The identified differences
       stress testing




                           proportionality                                                      seem to be justifiable by
                         • Insurance: no specific reference at L1, but several                  the specificities of each
                                                                                      Low
                           Consultation Papers containing advice on L2                          sector – hence there
                           implementing measures that deal with the issue of risk               does not seem to exist a
                           assessment and stress testing                                        case for harmonisation
                         • Securities: no requirements exist


              9 April 2010                                                                                         Page 21
                                                                                                                 CEIOPS


               Main findings
                       Risk management system

Area                                        Main findings                           DDH             Rationale
                                                                                            • High-level requirements
                                                                                              to implement
                                                                                              contingency and/or
 Business continuity




                       • Banking: the only additional requirement (at L3) is                  business continuity plans
                         related to the management of IT-related risks                        are generically
                       • Insurance: CEIOPS CP 33 refers to the need of                        equivalent
                         regularly testing and updating the existent business      Medium   • But the requirements to
                         continuity plans                                                     test and update the plan,
                       • Securities: the MiFID (L2) requires the definition of a              as well as the definition
                         business continuity policy                                           of a business continuity
                                                                                              policy seem to be
                                                                                              sensible requisites that
                                                                                              all sectors should have




              9 April 2010                                                                                      Page 22
                               CEIOPS


 Main findings
      Risk management system




9 April 2010                   Page 23
                                                                                                                        CEIOPS


                    Main findings
                            Internal control system

  Area                                            Main findings                          DDH              Rationale

                                                                                                 • Although not being a
Implementation of
an internal control




                                                                                                   critical issue, given that
                            • The provisions for implementing an internal control                  the recent financial crisis
      system




                              system are broadly similar                                           has revealed the
                                                                                         Low
                            • Insurance: there is an explicitly stated obligation to               importance of effective
                              have a written policy in relation to internal control                internal controls,
                                                                                                   harmonisation could be
                                                                                                   pursued in a near future

                            • The requirement to have a compliance function is
                              defined across all three sectors                                   • One of the most relevant
                            • Banking: L3 guidance includes specificities regarding                differences that exist
      Compliance function




                              the “head of the function”, including a requirement for              between the
                              the function to be “organisationally separate from the               requirements for each
                              activities it is assigned to monitor and control”                    sector is the concept of
                              (subject to the principle of proportionality)                        “independence”
                                                                                        Medium
                                                                                                 • The requirement to
                            • Insurance: no requirement for independence                           appoint a dedicated
                              regarding the compliance function exists (“appropriate               compliance officer could
                              standing” at L2)                                                     be important to the
                            • Securities: a dedicated officer must be appointed to                 achievement of good
                              the compliance function, not subject to proportionality              governance
                              considerations
                                                                                                                       CEIOPS


                  Main findings
                           Internal control system

Area                                            Main findings                            DDH             Rationale
                                                                                                 • Important constituting
                                                                                                   elements of how an
                                                                                                   internal audit function
                                                                                                   should be established
                                                                                                   and operate in
 Internal audit function




                           • The important cornerstones of an effective internal                   supervised entities, such
                             audit function, such as independence and reporting                    as independence and
                             requirements, are common to all three sectors                         scope of operation, are
                           • Banking and securities: the requirement of                            not always regulated in
                                                                                        Medium
                             independence is subject to the principle of                           binding directives
                             proportionality                                                     • Recommendations
                           • Insurance: proportionality is not applicable in relation              related to the operational
                             to the independence of the internal audit function                    independence of the
                                                                                                   internal audit function in
                                                                                                   the cases where the
                                                                                                   principle of
                                                                                                   proportionality applies
                                                                                                   could be useful




                 9 April 2010                                                                                         Page 25
                                CEIOPS


 Main findings
      Internal control system




9 April 2010                    Page 26
                                                                                                                        CEIOPS


                    Main findings
                              Supervisory review, internal reporting and public disclosure

Area                                               Main findings                           DDH             Rationale
                                                                                                   • A whole analysis and
                                                                                                     review of the supervisory
                                                                                                     review process, as well
                                                                                                     as its consequences, is
                                                                                                     performed
                              • There are requirements relating generally to the                   • Provide supervisors with
 Supervisory review process




                                obligations of regulators to monitor compliance by                   powers to assess:
                                entities with the relevant directive requirements, as                – The quality of the
                                well as to provide information to regulators to enable                 decision-making
                                them to carry out that monitoring                                      processes
                              • Insurance: Solvency II imposes a specific obligation on              – The “fit and proper”
                                                                                          Medium
                                regulators to be satisfied that the entity’s system of                 requirements of the
                                governance is adequate and requires entities to                        members of the
                                provide information that would enable the regulator to                 management body and
                                make that assessment                                                   senior management
                              • Securities: not so detailed requirements as banking                  – The effectiveness of
                                (SREP) and insurance (SRP)                                             the internal control
                                                                                                       procedures
                                                                                                     – The effectiveness of
                                                                                                       the risk management
                                                                                                       systems (including
                                                                                                       ORSA and ICAAP)
                                                                                                                CEIOPS


               Main findings
                        Supervisory review, internal reporting and public disclosure

  Area                                       Main findings                          DDH            Rationale
                        • Banking: the most relevant requirements relating to
                          the reporting lines are defined at L3
   Internal reporting




                        • Insurance: L1 (Art. 41) foresees “an effective system           • All sectoral principles and
     requirements




                          for ensuring the transmission of information”, but                rules recognise that
                          articles on the risk management system, internal                  effective governance and
                          control and internal audit provide further requirements   Low     effective board decision-
                          on the reporting of these specific subjects                       making depends on the
                        • Securities: effective internal reporting and                      quality and timeliness of
                          communication of information focus more on the                    the information received
                          trading activity of the investment firms than on their
                          financial standing and risk management
accountability issues
 transparency and




                                                                                          • Differences identified in
                        • Banking and insurance: disclosure focuses on the risks            the different reporting
    Disclosure,




                          the entity is exposed to                                          requirements reflect the
                        • Securities: no requirements on the financial standing     Low     different purposes and
                          and risk management on the entities – focus is more               objectives pursued by
                          on trading activities                                             the directives and the
                                                                                            relevant supervisors


              9 April 2010                                                                                      Page 28
                                                                 CEIOPS


 Main findings
      Supervisory review, internal reporting and public disclosure




9 April 2010                                                    Page 29
                                                                                                                       CEIOPS


               Main findings
                          Group structures and group specific issues

Area                                            Main findings                            DDH             Rationale
                                                                                                 • The reasons for the
Corporate structure and




                                                                                                   existing differences can
                          • Banking and insurance entities are required to have a                  be motivated by the
                            transparent corporate or organisational structure both
     organisation




                                                                                                   different approaches of
                            at solo and group level                                                CRD, Solvency II and
                          • Securities: the only specific requirement in this            Low       MiFID
                            context refers to the conflicts of interest policy, which            • L3 future guidance could
                            should take into account the situations where an                       be useful on:
                            entity is part of a group                                              – Know-Your-Structure
                                                                                                   – Matrix management
                                                                                                   – Plurality of functions
Risk management




                          • Banking and insurance: the provisions regarding risk
                            management for solo level entities are also applicable               • The objectives in the
                            to the group level (including ICAAP and ORSA)                          regulation for the sectors
     system




                          • Insurance: a specific provision regarding the               Medium     are different, but
                            centralisation of risk management exists                               changes are needed at
                          • Securities: no specific provisions related to risk                     solo level
                            management at the level of a group exist


              9 April 2010                                                                                            Page 30
                                                                                                                            CEIOPS


                       Main findings
                                Group structures and group specific issues

  Area                                               Main findings                           DDH              Rationale
                                • Banking and insurance: the provisions applicable to
      Internal control system




                                  solo level entities also extend to the group level
                                • Securities: no specific provisions for the group level
                                  exist                                                              • The objectives in the
                                • FCD*: establishes that the internal control                          regulation for the sectors
                                  mechanisms should consider the “capital adequacy to       Medium     are different, but
                                  identify and measure all material risks incurred and to              changes are needed at
                                  appropriately relate own funds to risks” and “sound                  solo level
                                  reporting and accounting procedures to identify,
                                  measure, monitor and control the intra-group
                                  transactions and the risk concentration”
and public disclosure
Supervisory review,




                                • Banking and insurance: provisions are similar (mainly              • Some level of
 internal reporting




                                  extending the solo requirements to the level of the                  harmonisation for the
                                  group), although for banking many are just implicit                  high-level principles
                                  – Disclosure requirements are based on the                           could be achieved
                                                                                             Low
                                    consolidated financial situation                                   (including the
                                                                                                       supplementary
                                  – Reporting of intra-group transactions                              supervision of FiCos) –
                                • Securities: no specific requirements in this respect                 but this is not prioritary


                      9 April 2010                     * FCD = Financial Conglomerates Directive                            Page 31
                                                   CEIOPS


 Main findings
      Group structures and group specific issues




9 April 2010                                       Page 32
                                                                     CEIOPS


 Main findings
      Main differences and commonalities

• Existing internal governance requirements for the activities
  undertaken in the banking, insurance and securities sectors
  are generally similar and have the same intended
  outcomes or comparable outcomes
• For the majority of the internal governance aspects that
  were analysed, many requirements are set at different
  levels in different sectors
    – It was often observed that high-level principles for internal
      governance that e.g. are defined in the Level 1 directive for the
      insurance sector are only detailed in Level 3 for the banking
      sector




9 April 2010                                                         Page 33
                                                                             CEIOPS


   Main findings
      Main differences and commonalities

  • Some differences in the terminology used – or in its
    interpretation – were also identified, which the TFIG
    considers would benefit from some further standardisation to
    promote further convergence between sectors
    – Principle of proportionality – it is applicable to most of the
      requirements on internal governance entities are subject to

               Proportionality applies to internal governance policies
               Supervisory authorities will adapt their supervisory approach to
Banking
                ensure it is proportionate to the nature, scale and complexity of
                the activities of an entity

               The principle of proportionality does not justify the non-
Insurance
                application of any sort of requirements

               The proportionality principle is dealt with slightly differently
Securities
                (wording is often “shall where appropriate and proportionate)
                                                                      CEIOPS


 Main findings
   Main differences and commonalities

• Some differences in the terminology used – or in its
  interpretation – were also identified, which the TFIG
  considers would benefit from some further standardisation to
  promote further convergence between sectors (cont.)
 – Concept of “independence”
   • Does it always imply an organisationally separate unit?
 – Concept of “function”
   • E.g. In Solvency II, it is “an administrative capacity to undertake
     particular governance tasks”
                                                          CEIOPS


 Main findings
      Main differences and commonalities

• With regard to the differences between MiFID and CRD,
  further harmonisation of Level 1 and 2 provisions could be
  considered in order to reduce the number of different
  requirements for banks that also undertake investment
  activities




9 April 2010                                              Page 36
                                                                  CEIOPS




       3L3 Task Force on Internal Governance


       Cross-sectoral stock-take on internal governance issues


       Main findings


       Next steps




9 April 2010                                                      Page 37
                                                                    CEIOPS


 Next steps

• The TFIG considers that guidance would be beneficial on:
    – Management of conflicts of interest
    – Policies, processes and procedures related to the risks covered
      by the risk management systems
    – How the risk management, compliance and internal audit
      functions might be “independent” in the light of their different
      sectoral requirements
    – The supervisory review process




9 April 2010                                                        Page 38
                                                                                CEIOPS


 Next steps

• The development of guidance in these areas would:
    – Contribute to a more harmonised interpretation                    of     the
      requirements applicable to each type of activities
    – Complement the existing gaps between sectors in the cases
      where no specific requirements exist




        Further work to be developed will depend on the results of the “Call
          for Evidence” process and the conclusions to be taken thereof.




9 April 2010                                                                    Page 39
                            CEIOPS




               QUESTIONS?


9 April 2010                Page 40
 Thank you!
ana.byrne@isp.pt




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