How will this change the licence process for traditional and FinTech firms and what clarifications are provided on the CRR/CRD IV Framework?
21 September 2017 marked the end of summer. It also marked the start of the supervisory and regulatory publications "season" for the EU-27 and equally the Eurozone-19's Banking Union. The European Central Bank (ECB), as the lead within the Single Supervisory Mechanism (SSM) pillar of Banking Union published two supervisory "Guides" on licence applications. These apply to applicants requiring a licence for traditional as well as FinTech banking sector activity. The ECB-SSM is the ultimate decision maker on all banking licence applications in the Eurozone-19 and its Banking Union. This Client Alert assesses the practical impacts of these Guides and how they apply to traditional and FinTech credit institutions. Given the heightened volume of licence applications and the long lead timelines, market participants ought to assess and take action now.