Communication with the supervisor prior to the official submission of an application for authorisation (Pre-application phase) (for a credit or financial institution or (re)insurance undertaking)

The Bank of Greece (BoG) introduces a pre-application procedure to facilitate candidates interested in establishing a credit or financial institution or (re)insurance undertaking. 

This is an optional procedure prior to the submission of the formal application for authorisation.

The aim of this procedure is to:

  • enable interested parties to understand the supervisory expectations for granting authorisation to establish and operate a credit or financial institution or (re)insurance undertaking under the applicable institutional and regulatory framework, so that they may submit complete files with all the required data;
  • highlight issues where more preparation by interested parties is needed. 

Applicants’ understanding of supervisory expectations and effective management of issues that will emerge during the pre-application procedure should result in the submission of a more complete file and in the avoidance of delays during the assessment to be carried out after the application for authorisation has been submitted.

In order to make the best use of the procedure, it is recommended that interested parties prepare their proposal adequately.

What does the pre-application procedure involve?

It involves two (2) meetings between interested parties and BoG staff, which can be held in person, online or in a hybrid manner.

It involves two (2) meetings between interested parties and BoG staff, which can be held in person, online or in a hybrid manner.

In the first meeting, which is of an introductory nature, issues concerning the shareholders of the new institution, its business model, the paying-up of the initial capital, any intra-group loans or transactions, etc. are discussed.

Other issues could be discussed on an optional basis, such as: the organisational structure, the governance framework and internal control mechanisms, the prospective members of the Board of Directors, any planned outsourcing of functions, as well as the timeline for the establishment of the new institution.

In the second meeting, which is of a more technical nature, the business plan, the viability of the business model and the ability of the new institution to comply with supervisory requirements are discussed.  

Where appropriate, a single meeting may be held on both introductory and technical issues.

To facilitate the discussion, interested parties should send relevant material electronically before a meeting is scheduled.

For the authorisation of a credit institution, microfinance institution, credit servicing firm, leasing, credit or factoring company, the relevant material should be sent to dep.bankingsupervision@bankofgreece.gr.

For the authorisation of a payment institution, electronic money institution or bureau de change, the relevant material should be sent to sec.paymentemoneyins@bankofgreece.gr.

For the authorisation of a (re)insurance undertaking, the relevant material should be sent to dep.insurancesup@bankofgreece.gr.

Any comments, defects or improvements discussed at the above meetings, during the pre-application procedure, should be taken into account by interested parties when preparing the final file and submitting the application for authorisation.

Content Editor

​Important remarks

The conduct of this procedure does not preclude further data being requested during the review of the official file and does not prejudge the outcome of the assessment and the final decision. 

Specifically with regard to the authorisation of a credit institution, it should be noted that the final decision is taken by the ECB, in accordance with Article 14 of Council Regulation (EU) No 1024/2013 of 15 October 2013.

The pre-application procedure is not advisory in nature and may not cover all the required aspects of the authorisation procedure. In this sense, interested parties remain under an obligation to present a complete file at the time of submission of the formal application.  

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