Response to consultation on draft RTS on the procedure for the approval of white papers of ARTs issued by credit institutions

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Question 1. Do you agree with the 20-working day period for the assessment of completeness of the crypto-asset white paper, as regulated under Article 3?

We definitely agree on the 20-working day period for the assessment of completeness of the crypto-asset white paper: we believe that providing the market with a definite deadline to carry out such assessments is a very positive signal of systemic efficiency.

Question 2. Do you agree with the rules, as regulated under Article 4, on the request of missing information to a crypto-asset white paper, including on the 20-working day period for the deadline to provide missing information?

We definitely agree on the rules concerning the request of missing information in a crypto-asset white paper, including on the 20-working day period to provide missing information: as previously stated, we think it is a very positive signal of systemic efficiency.

Question 3. Do you agree with the rule, as regulated under Article 6, that where the ECB and, where applicable, another central bank do not transmit an opinion to the relevant competent authority within the set deadline, the latter may consider this as an indication that there is no negative opinion on the grounds of a risk posed to the smooth operation of payment systems, monetary policy transmission, or monetary sovereignty?

We agree with the rule included in Article 6. We think that also this provision leads to an improvement of the systemic efficiency.

Question 4. Do you agree with the possibility that, in the context of the substantive review of the crypto-asset white paper, the competent authority can request of changes to a crypto-asset white paper, and the rules on that request, as regulated under Article 7?

We agree with the possibility that, in the context of the substantive review of the crypto-asset white paper, the competent authority can request changes to a crypto-asset white paper as laid down in Article 7. However, we believe that the deadline for providing the updated crypto-asset white paper requested by the competent authority (paragraph 2) should not exceed 20 working days (instead of 10 working days) following the issuance of the request for changes by the competent authority. This in order to have it aligned with previous, 20-working-day deadlines included in the RTS.

Name of the organization

ANASF