Submission #7

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KBC GROUP

Question 1: Do you agree that requiring the credit institution submitting the passport notification to indicate the intended start date of each activity which the notification refers to, rather than only the core activities, will support the competent authorities’ comprehensive and accurate assessment of the passport notification and provide them with an accurate picture of the credit institution’s planned activities as well as their ability to carry them on?

We are of the opinion that the whole passport process should be simplified, especially for Free Provision of Services (see the slides attached to our answer for an overview of our arguments and the proposed solutions)

Question 2: Do you agree that the indication of the underlying assumption used to develop the forecastswill support the competent authorities’ comprehensive and accurate assessment of the branch passport notification? Yes

Question 3: Do you agree that requesting a statement by an external auditor that the credit institution no longer holds deposits or other repayable funds from the public through the branch in the relevant host Member State is adequate to ensure the transparency of the process and the protection of depositors? We do not see the added value of this statement.

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Name of the organization KBC GROUP