Submission #6

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GLEIF (Global Legal Entity Identifier Foundation)

1) Do you agree with the draft RTS on passport notifications under the PSD2? If not, outline why you disagree and how the RTS could be improved?

Non-Applicable. Comments provided on behalf of GLEIF will be limited to the use of LEIs in regard to PSD2.

2) Do you agree with the format of the relevant unique identification number in each Member State set out in Annex I? If not, please outline which content you disagree with, why you disagree and how the format could be improved.

The format of the relevant unique identification number for legal persons could be improved by requiring the use of the Legal Entity Identifier (LEI) consistently by all Member States for this identifier. In Annex 1, only one Member State, Spain, has indicated the use of the LEI for this identifier, with most of the Member States proposing different national identifiers.

The EBA has been supportive of the LEI and its use its related benefits by requiring LEIs to be used in supervisory reporting. GLEIF hopes that the EBA also will see the benefits that using the LEI will bring for the exchange of information between competent authorities for passporting under Article 28(5) of the revised Payment Services Directive (PSD2).

3) Do you agree with the draft notification form for branch passporting set out in Annex II? If not, please outline which content you disagree with, why you disagree and how the notification form could be improved.

Non-Applicable. Comments provided on behalf of GLEIF will be limited to the use of LEIs in regard to PSD2.

4) Do you agree with the draft notification form for agent/distributor passporting set out in Annex III? If not, please outline which content you disagree with, why you disagree and how the notification form could be improved

Non-Applicable. Comments provided on behalf of GLEIF will be limited to the use of LEIs in regard to PSD2.

5) Do you agree with the draft notification form for the passporting of services set out in Annex IV? If not, please outline which content you disagree with, why you disagree and how the notification form could be improved.

Non-Applicable. Comments provided on behalf of GLEIF will be limited to the use of LEIs in regard to PSD2.

6) Do you agree with the draft notification form for the start of branch/agent/distributor passporting activities as set out in Annex V? If not, please outline which content you disagree with, why you disagree and how the notification form could be improved.

Non-Applicable. Comments provided on behalf of GLEIF will be limited to the use of LEIs in regard to PSD2.

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Name of organisation GLEIF (Global Legal Entity Identifier Foundation)