1. Domino Group – Recovery Plan Assessment

2. Governance Deficiencies and impediments identified:
Development, maintenance and updating of the recovery plan - Art. 5 (a)(i) and (ii), (b) RTS Content of RP
The plan has not been reviewed and approved by the Management Body or the Board of the Bank.
There is no information on the person who has overall responsibility for the plan and provide leadership and direction and be accountable to the Board.
No statement that plan has been reviewed by Internal Audit, External Audit or Risk Committee.
No detailed procedures for plan maintenance, testing and updating annually and for when changes to the plan are required and the requirements for Board approval for any changes.

3. Cont.
Integration and consistency of the recovery plan with the institution`s governance and internal procedures - Art. 5 (a)(iii) and (iv) RTS Content of RP
No evidence provided of the governance of the recovery plan being integrated into the governance and risk management structure.
No details have been provided in relation to the Management Information Systems.
3. Escalation procedures - - Art. 5 (c)(i) and Art. 5 (e) RTS Content of RP
There is no written procedures detailing the roles and responsibilities of executives and committees at each stage of the escalation process.
Lack of information on requirement to inform competent authority.
There is no information on consistency of Group plan with the plans of separately supervised subsidiaries (e.g. regarding governance and any legal restrictions).
There is no internal and external communication plan.