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We consider that the objectives of the guidelines as identified by the EBA are plausible and complete.
We agree that the options chosen by the EBA are the preferred ones.
Both the detailed description of the services the applicant intend to provide, and the fact that there is a complete list of information items to provide will enable CAs to process the application faster and more reliably.
The three-part structure of the guidelines will help applicants provide more focused information, in turn helping the CAs process the application.
The proportionality measures incorporated in the guidelines are needed in order to adapt the measures, processes and solutions to the scale of the applicant’s activity.
We think that they should be more explicitly detailed, as there is a lot of room for interpretation in the way they are integrated in the guidelines.
Amongst the objectives of the guidelines is the fact that they should provide a level playing field, guaranteeing that all applicants should be treated the same regardless of the CA to which they apply, and we feel that to fulfill this goal, the proportionality measures should be more explicit.
Not applicable to our case.
The sheer amount of information items the applicant needs to provide in its application will deter small, innovative new entrants, which seems to be in direct opposition to the EBA’s mission statement.
The proportionality measures could be a good way to compensate for this issue, but the way they are laid out is prone to open interpretation, thus raising the uncertainty and lowering the transparency for the applicants.
These measures should be made explicit and detailed.
Not applicable to our case.
In our view, this guideline should also include the obligations of the CA regarding the evaluation process. Article 12 of PSD2 explicitly states that CA should grant or refuse the authorization within 3 month of receiving all information required for the decision, as well as the fact that refusal have to be motivated.
As the guidelines are legally binding, they should include both these obligations.