In general, the EACB welcomes the ECB initiative to introduce a consistent approach to the assessment of licence applications for new FinTech banks. We appreciate the ECB’s objective to ensure that FinTech banks uphold the same standards as all credit institutions in terms of licence requirements. It is of the utmost importance that all players compete on a level playing field regardless on whether they are banks, FinTechs or other tech companies (e.g. Google, Apple, etc.). Capital requirements should clearly be adjusted to cater for the risks entailed and the principle of “same services, same risks, same rules and same supervision” should apply. However, the Draft Guide is not sufficiently detailed on some of the assessment criteria, for example regarding capital and liquidity requirements (Chapter 6), which are fundamental issues for credit institutions, e.g. no “assessment box” is provided.
2 November 2017
ECB Public consultation on the draft Guide to assessments of fintech credit institution licence applications