In assessing whether the systems and controls used by the Digital Investment Manager are adequate and appropriate for the scale and nature of its business, the FSRA may have regard to the following:
a. the distribution of duties and responsibilities among its key individuals;
b. the staffing and resources of the Digital Investment Manager;
c. the arrangements made to enable key individuals to supervise the operations of the Digital Investment Manager; and
d. the arrangements for internal and external audit, including technology audits.