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Supervisory Issues

Management Autonomy

80. In financial conglomerates, there can also be a question as to whether the management of a supervised entity has sufficient independence and authority to be able to meet the demands of the regulators. In cases where independence and authority are lacking, it is usually because there is a conflict between the supervisor's requirements of the management and the demands placed on management either by the shareholders themselves or by the management of other more influential parts of the group. To help ensure appropriate management autonomy, it is important for supervisors to know who is exercising control over the regulated arms of a conglomerate; in particular, supervisors should know who is responsible for compliance with legal and supervisory requirements. Furthermore, supervisors need to be informed not only of significant changes in shareholders, but also of significant management changes within the conglomerate as a whole, including those changes taking place in the unsupervised holding or parent companies which involve persons who may be able to influence the management or policies of a regulated entity.

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