Positionspapier Bitkom-Position on ECB Consultation on guides concerning the assessment of fintech credit institution licence applications
In September, the European Central Bank (ECB) published its consultation paper on “Guides concerning the assessment of fintech credit institution licence applications” and invited to comment on it. The consultation contains two documents: The first sets out the general process and requirements for assessing banking licence applications. The second document is directed at entities with a fintech business model that are considering applying for a banking licence.
Bitkom has only commented on the second document. Bitkom points out that most of the requirements outlined in the draft guide are not specific to fintech banks. The Position Paper strongly supports applying the principle of “a level-playing field / same business same rules” and the principle of proportionality in regulation. The guide deviates from such an approach. This relates in particular to the points: suitability of shareholders, credit scoring model and exit plan.