On October 25, 2023, De Nederlandsche Bank (DNB) consulted the "Good practices Handreiking prudential reports for investment firms and investment fund managers". With the handbook, DNB wants to give investment firms and managers of investment institutions and UCITS (hereinafter: institutions) more guidance on how to correctly complete and submit and provide an overview of good practices for prudential reporting. We responded to this consultation on December 13, 2023.
Added value Good Practices?
The good practices consulted do not seem to be "real" good practices, but more principles or principles. While the added value can lie precisely in explanation of concrete methods. In addition, we believe there are better ways to improve the quality of reporting, such as by applying more customization in DNB's questioning. Also, DNB could provide better explanation and context to the questions, taking into account the target audience of the query. From the many existing manuals and FAQs that have been published, it can be seen that the current reports are complex and there is room for simplification and improvement.
Basis of good practices focused on banks
The good practices are 90% based on the Basel Principles intended for banks. We believe that these should be more recognizably tailored to the specific activities, (risk) profile and size of managers of investment institutions. In this regard, it is recommended that DNB also specifically indicate what experiences with the reporting of investment firms and managers of investment institutions make the drafting of good practices necessary.
