Description
Role Summary
Provide an independent advisory review of Credendo’s proposed response to the National Bank of Belgium (NBB) regarding DORA compliance for Credendo TCI and Credendo GSR. The consultant will assess the reasonableness of compliance positions, the application of the proportionality principle, and provide regulatory observations and recommendations to strengthen Credendo’s approach.
Key Responsibilities
DORA Compliance Assessment
- Review Credendo’s proposed DORA compliance positions across selected domains.
- Assess the reasonableness and defensibility of compliance interpretations from a supervisory perspective.
- Evaluate the application of the proportionality principle within the selected DORA domains.
- Review alignment with DORA requirements, RTS/ITS guidance, and supervisory expectations.
Regulatory Response Review
- Review the structure, logic, and consistency of the proposed response to the National Bank of Belgium.
- Challenge key compliance assertions and assumptions.
- Identify potential regulatory gaps, weaknesses, or inconsistencies.
- Assess the overall regulatory defensibility of the proposed positions.
Advisory & Recommendations
- Provide independent professional observations on compliance positions.
- Recommend improvements to strengthen the regulatory response.
- Propose enhancements to governance, ICT risk management, and compliance documentation where relevant.
- Prepare a concise advisory memorandum summarizing findings and recommendations.
Required Experience
- Strong knowledge of DORA (Digital Operational Resilience Act).
- Experience with ICT risk management frameworks and financial sector regulations.
- Experience performing regulatory assessments, gap analyses, or second-line reviews.
- Knowledge of proportionality principles within European financial regulations.
- Experience interacting with financial regulators or supporting regulatory inspections.
- Understanding of Third-Party Risk Management (TPRM), ICT Governance, Operational Resilience, and Information Security frameworks.
Key Skills
- Regulatory Compliance & Risk Management
- DORA & ICT Governance
- Supervisory Review & Challenge
- Regulatory Response Assessment
- Stakeholder Management
- Advisory Reporting
- Gap Analysis & Compliance Assessment
- Financial Services Regulatory Environment
Deliverables
- Proportionality assessment across selected DORA domains.
- High-level review of Credendo’s proposed NBB response.
- Advisory memorandum with observations and recommendations.
- Executive management presentation (if required).
