Participants in the communication

The supervisory team leader and the key audit partner should be the primary participants in the communication.

In cases when the communication occurs between individuals other than the supervisory team leader and the key audit partner, both the supervisory team leader and the key audit partner should be informed by their respective parties about the issues discussed and the outcome of such communication without undue delay.

Competent authorities should assess the usefulness of organising trilateral meetings, in particular where in-depth communication is applied. In making this assessment, competent authorities should consider whether:

• a. clarifications from the credit institution’s management body, senior management or audit committee, or a body performing equivalent functions within the credit institution, are deemed necessary for a particular issue to be discussed between competent authorities and auditors
• b. coordination of actions across the competent authority, auditor and credit institution are necessary.

When trilateral meetings are organised, they should be in addition to any bilateral meetings. Trilateral meetings may include members of the credit institution’s audit committee, internal auditors, experts on relevant key control functions, or members of the credit institution’s management body and senior management as necessary.

If in the competent authority’s judgement it would facilitate the exercise of supervisory tasks, and subject to professional secrecy conditions required by Union or national law, competent authorities may invite other relevant public authorities (such as those responsible for the supervision of financial markets, the public oversight of auditors or the resolution of credit institutions) to the meetings with the auditors or inform these authorities of the outcome of the discussions with the auditors.

Effective communication between competent authorities and auditors should include adequate safeguards for the continuity of the communication regardless of the turnover of staff involved. Competent authorities should keep their own internal records of the communication to ensure that successors of the staff previously participating in the communication are able to obtain sufficient information about the communication performed in the past. This information may include:

• a. minutes of communications or a summary of minutes
• b. key issues discussed
• c. conclusions of discussions
• d. future actions.