The Dutch Authority for the Financial Markets (AFM) has introduced guidelines for investment firms, AIFMs and management companies to improve incident notification practices.
After conducting a detailed review, AFM identified several reasons for firms not adequately reporting incidents. The findings are presented in a report containing suggested best practices.
Key observations from the review include:
– Some firms lack well-defined policies and procedures for identifying incidents
– There are discrepancies in how firms define and handle incidents
– Incident notification processes are sometimes incomplete, lacking clear roles and instructions
– Documentation of decision-making related to incidents is often insufficient
– Certain firms overly prioritize operational incidents, neglecting interpersonal issues
– Some firms heavily rely on staff judgment for incident assessment, leading to inconsistent outcomes
The review was initiated due to the low number of incident notifications received by AFM. The organization has been focusing on incidents in investment firms since 2020 and aims to address the reasons behind the lack of incident reporting.
To ensure the asset management sector operates effectively, it is crucial for firms to promptly notify AFM about incidents. This facilitates timely responses and contributes to issue resolution. A well-functioning sector benefits both firms and investors.