Yes except q. 130/ it is not clear when the appointment should be made especially if the shareholders decide to nominate and appoint a director at the AGM when there is insufficient time for the institution to fully assess a candidate and apply for an assessment by the competent authority
No they are not clear. As above what happens when shareholders have the right to nominate and appoint members of the Board of Directors (q. 166)
Ex-ante assessment would mean that shareholders would need to nominate members at least 4 months ahead of the AGM? Also when recruiting heads of control functions or other senior managment postiions, appointments would need to be put on hold for four months. Candidates could possibly lose interet and find alternative employment posts.
It is difficult to foresee any direct or eve indirect costs except as mentioned above.
The costs of replacing the appointed person and starting the process again is one but is it difficule to foresse any direct or indirect costs.
Not as far as the ex-ante assessment by the competent authorities is concerned
It appears excessive and inappropriately complicated
They appear excessive
It is difficult to put a number on the financial costs of complying with the guidelines. In terms of cost it would mean a dedicated unit (as already most of the guidelines have beeen adopted and are in place) to run the whole process of assessing candidates and re-assessing existing members of the managment unit, assissing the performance of the managment body, ensuring proper training etc. It would mean the cost of recruitment agencies to find appropriate candidates within the diversity policy of the institution and the cost of collecting all the necessary information before assessment can be made.