DNB investigates EGIs and PSPs; three practical tips

At the end of the summer, DNB announced that it will investigate fast-growing EGIs and PSPs and assess their management of integrity risks. In a first round, a questionnaire is distributed. Based on the responses, DNB will select several institutions that will be investigated thoroughly in 2023. We have three tips from our practice that may help you:

1) A different perspective. Use the questionnaire to view your own organization through DNB’s critical eyes. Points for improvement are usually known, but for all sorts of justified reasons they may not have been given priority. In that case these issues have not yet been resolved. Time to re-evaluate priorities.

2) Honesty lasts the longest. Give real and true answers and avoid misrepresentation. However, questions can often only be answered in the format prescribed by DNB. That usually means there is no room for explanation, context and nuance. If answers require more explanation than the question form offers, please inform DNB separately by sending an additional explanation. DNB should be offered information to get a clear picture of your organization.

3) Take the flight forward. By answering questions you may learn that there is room for improvement. Make a plan and act. When repairs have to be made, it is better to do it quickly on your own initiative than to get forced by the supervisor. Finnius has endless experience with supervisory investigations and subsequent enforcement by DNB. Use it to your advantage.