Submission #20

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Bank Zachodni WBK S.A.

Question 1: Do you consider the objectives of the Guidelines as identified by the EBA to be plausible and complete? If not, please provide your reasoning. NA

Question 2: Do you agree with the options the EBA has chosen regarding the identification of payment services by the applicant; the way information is to be submitted to the competent authority; the four-part structure of the Guidelines, and the inclusion of authorisation for electronic money institutions? If not, please provide your reasoning. NA

Question 3: Do you consider it helpful how the EBA has incorporated proportionality measures in the Guidelines in line with PSD2? If not, please explain your reasoning and propose alternative approaches. NA

Question 4: Do you agree with the Guidelines on information required from applicants for the authorisation as payment institutions for the provision of services 1-8 of Annex I of PSD2, as set out in chapter 4.1? If not, please provide your reasoning. NA

Question 5: Do you agree with the Guidelines on information required from applicants for registration for the provision of only service 8 of Annex I PSD2 (account information services), as set out in chapter 4.2? If not, please provide your reasoning.

1) It seems that applicant which is currently being regulated by a competent authority and at the same time registered as account service provider (bank) that already has an authorization for payment services should be revoked from the requirements. In addition since the competent authority is in possession of the information as listed in guidelines and it has not changed, the EBA should take such an exception into consideration.
2) We are of the opinion that the EBA should analyze the necessity of providing the copy of an official identity document or equivalent of directors and persons responsible for the management of the electronic money institution/of the account information service provider due to the all risks according to collecting identity information /Guidelines part 4.2 , 11.1 a) /

Question 6: Do you agree with the Guidelines on information requirements for applicants for authorisation as electronic money institutions, as set out in chapter 4.3? If not, please provide your reasoning.

Question 7: Do you consider the Guidelines regarding the assessment of completeness of the application, as set out in chapter 4.4 to be helpful? If not, please provide your reasoning. na

Name of organisation Bank Zachodni WBK S.A.