(3) For the purpose of determining the annual premium of a member institution for a premium year, a reference in this By-law to the Guidelines for Banks, the Guidelines for Trust and Loan Companies or the Reporting Manual is a reference to that publication as amended up to and including October 31 preceding the premium year.

41. Notes that seconded national experts, external and interim staff are not specifically mentioned in the guidelines and that especially in the case of so-called independent experts, there is still room for interpretation, for example, in the case of academics who have also undertaken research for individual companies or the business community at large; calls upon the Network to ensure a harmonised approach in this respect, which will also prevent any indirect conflicts of interest;

40. Notes that seconded national experts, external and interim staff are not specifically mentioned in the guidelines and that especially in the case of so-called independent experts, there is still room for interpretation, for example, in the case of academics who have also undertaken research for individual companies or the business community at large; calls upon the Network to ensure a harmonised approach in this respect, which will also prevent any indirect conflicts of interest;

F. whereas the guidelines call for monetisation of impacts wherever possible; whereas, while short-term costs to business can normally be monetised, long-term benefits of regulatory action are often impossible to quantify in monetary terms (for example, reducing health impairments or maintaining eco-systems); whereas the emphasis on quantification wherever possible therefore introduces a structural bias in favour of more easily quantifiable aspects such as costs to economic operators as compared with social and environmental benefits, thus failing to adequately consider societal ...[+++] costs and benefits as a whole, and in particular social and environmental costs and benefits;

F. whereas the guidelines call for monetisation of impacts wherever possible; whereas, while short-term costs to business can normally be monetised, long-term benefits of regulatory action are often impossible to quantify in monetary terms (for example, reducing health impairments or maintaining eco-systems); whereas the emphasis on quantification wherever possible therefore introduces a structural bias in favour of more easily quantifiable aspects such as costs to economic operators as compared with social and environmental benefits, thus failing to adequately consider societal ...[+++] costs and benefits as a whole, and in particular social and environmental costs and benefits;

Although the scope of the directive has been extended to cover life insurance intermediaries and trust and company service providers, once again the intention is not that these professional groups should come under any general suspicion of involvement in money laundering.