ACCIS members are committed to building a thriving and globally competitive European financial services sector. While preserving their core values of trust, privacy and security, Credit Referencing Agencies (CRAs) are early developers and adopters of innovative financial technologies for the benefit of both individual consumers (B2C) and firms (B2B). CRAs do consider themselves active members of the FinTech ecosystem. It is from that perspective that we are glad to contribute to this consultation process. We have provided feedback to those questions relevant for CRAs.