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Bank Zachodni WBK S.A.

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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) /
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 part 4.3 , 16.1 a)/
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Alina Ofierska - Danielewicz
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