19. Assessment of the collective suitability of the management body

When assessing the collective suitability of the management body, institutions should assess the composition of the management body in its management and supervisory functions separately. The assessment of collective suitability should provide a comparison between the actual composition of the management body and the management body’s actual collective knowledge, skills and experience, and the required collective suitability pursuant to Article 91(7) of Directive 2013/36/EU.

Institutions should perform an assessment of the collective suitability of the management body using either:

• a. the suitability matrix template included in Annex I. Institutions may adapt this template taking into account the criteria described in Title I; or
• b. their own appropriate methodology in line with the criteria set out in these Guidelines.

When assessing the suitability of an individual member of the management body, institutions should, within the same time period, also assess the collective suitability of the management body in accordance with section 7 as well as whether or not the overall composition of the specialised committees of the management body in its supervisory function is adequate³³ . In particular, it should be assessed what knowledge, skills and experience the individual brings to the collective suitability of the management body and whether the overall composition of the management body reflects an adequately broad range of knowledge, skills and experience to understand the inst itution’s activities and main risks.

³³ Regarding the composition of committees please refer also to the relevant EBA Guidelines on Internal Governance.

When assessing the collective suitability in line with Title III (7), institutions should also assess whether the management body through its decisions has demonstrated a sufficient understanding of ML/TF risks and how these affect the institution’s activi ties, and has demonstrated appropriate management of these risks, including corrective measures where necessary.