Submission #169

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QUESTIONS

1. In which Member State is your institution established? NA

2. Please provide information on the type or nature of customers or categories of customers you have decided not to service and/or on the financial products you have withdrawn from providing. NA

Please provide quantitative data where possible in support of your response (e.g., how often this type of decisions are taken per calendar year, an estimate % this represents in the total number of your business relationships, etc.). NA

3. Which risk factors does your institution consider when assessing whether to withdraw from serving certain customers or categories of customers or from offering certain products? In your experience, is one risk factor more important than others? If so, which one? NA

4. What measures (such as offering alternative products, increasing the price for an existing product, or restricting the features of an existing product) has your institution taken to mitigate potential detriment arising from your de-risking decision? NA

6. In which Member State is the financial institution that decided not to have/withdraw business relationship with you established? The Netherlands

7. Which financial product have you been denied access to? Opening bank accounts

8. How did it affect you and what was the concrete impact of this decision?

New Client could not open bank accounts meaning that these clients have to find FinTech solutions or open an new entity in another country. The same applied for my own organisation

Please provide quantitative data where possible in support of your response. Only existing clients but no new clients can open bank accounts

9. How was the decision not to have/withdraw a business relationship with you explained by the financial institution?

Explained as internal decision based upon risk not to comply with the requiremenst of Dutch Central Bank

10. Were you given an opportunity to have this decision reviewed and if so, what was the process involved with what outcome? Please provide details. We could review but it did not change their decision

11. Were you able to use alternative channels to access financial services? Please explain. Fintech solutions

Type of organisation: Others

If you selected “Financial Institutions”, please specify the type here:

If you selected ‘others’, please specify here: Corporate service provider

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Name of the organization Alter Domus The Netherlands

Contact name Therese Wijnen