Submission #4

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Caixa Geral de Depósitos, S.A.

Q1. Do you agree on the application of the JC Guidelines to credit intermediaries and non-credit institution creditors under MCD? If not, please provide your reasoning. Yes.

Q2. Do you agree on the application of the JC Guidelines to PISPs that provide only payment initiation services, but no other payment services, under PSD2? If not, please provide your reasoning. Yes.

Q3. Do you agree on the application of the JC Guidelines to RAISP under PSD2, albeit limited to security-related complaints only? If not, please provide your reasoning. Yes.

Q4. Do you agree with the view of the EBA that the JC Guidelines should apply to RAISPs, non-credit institution creditors and credit intermediaries that are natural persons? If not, please provide your reasoning. Yes.

Q5. Do you agree with the view proposed by the EBA that proportionality should be applied in a general way to the activities of RAISPs, non-credit institution creditors and credit intermediaries and that they should not be exempted from any of the requirements of the Guidelines? If not, please provide your reasoning. Yes.

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Name of organisation Caixa Geral de Depósitos, S.A.