Is it possible for internal control staff and risk management staff to start work after the operating license is obtained?
In operating license applications to our Institution, as of the application date, the internal control and risk management units must have been established, and the staff who will work in these units, along with their job descriptions, powers and responsibilities, must have been determined.
Why should they be ready before applying?
The regulator wants to see that the institution is operationally ready before it is licensed. Internal control and risk management are the foundation of an institution's ability to supervise itself.
At the application stage, these units must be defined, even if only on paper, and their job descriptions, reporting lines and powers must be set. Even if staff can be appointed later, the structure and responsibilities are expected to be clear in advance.
Small institutions may support this function with external services, but the independence requirements in the legislation must be observed.
