EN ECB -PUBLIC  
 
OPINION OF THE EUROPEAN CENTRAL BANK  
of 15 February 2018  
on conferring new tasks relating to interchange fees for card -based payment transactions  to the 
Bank of Greece  
(CON/20 18/11) 
 
Introduction and legal basis  
On 3 January 2018 the European Central Bank (ECB) received a request from the Greek Ministry of 
Finance for an opinion on a draft law on measures implementing Regulation (EU) 2015/751 of the 
European Parliament and of the Council of 29 April 2015 on interchange fees for card- based payment 
transactio ns1 (hereinafter  the ‘draft law’) . 
The ECB’s competence to deliver an opinion is based on Articles 127(4) and 282(5) of the Treaty on the 
Functioning of the European Union and the third indent of Article  2(1) of Council Decision 98/415/EC2, as 
the draft la w relates to the Bank of Greece.  In accordance with the first sentence of Article 17.5 of the 
Rules of Procedure of the European Central Bank, the Governing Council has adopted this opinion.  
 
1. Purpose of the draft law  
1.1 The purpose of the draft law is to intr oduce implementing measures in respect of Regulation 
(EU) 2015/751, by designating the competent authorities empowered to ensure the application of  
its provisions and to impose penalties in cases of infringement . Regulation (EU) 2015/751 imposes 
a maximum cap on interchange fees and lays down technical and business requirements for card-
based payment transactions , which primarily aim to promote the use of electronic payment  
instruments  for the benefit of payees and consumers , as well as to  creat e a level pl aying field and 
to promot e competition among players in the market for card payments.  
1.2 The draft law designates the Bank of Greece as the main competent authority  responsible for 
ensuring the enforcement of the majority of the provisions of Regulation (EU) 2015/7513, and for 
imposing penalties on payment service providers in cases of infringement. Furthermore, t he draft 
law designates the General Secretariat  for Commerce and Consumer Protection of the Ministry of 
Economy and Development  as the competent authority responsible for ensuring compliance with 
                                                 
1  Regulation (EU) 2015/751 of the European Parliament and of the Council of 29 April 2015 on interchange fees for 
card- based payment transactions ( OJ L 123, 19.5.2015, p. 1).  
2    Council Decision 98/415/EC of 29 June 1998 on the consultation of the European Central Bank by national 
authorities regarding draft legislative provisions (OJ L 189, 3.7.1998, p. 42).  
3   Articles 3, 4, 6, 7, 8 (except for 8(2)), 9, 10 (except for 10(4)), 11 and 12 of Regulation (EU) 2015/751.  
ECB -PUBLIC  
2 all remaining obligations under Regulation (EU) 2015/7514, i.e. those not assigned to the Bank of 
Greece.  
1.3 More specifically, under the draft law , the Bank of Greece is responsible for  monitoring and 
ensuring the application of  a maximum cap on interchange fees  for consumer debit card 
transactions of no more than 0. 20 % of the transaction value, and a cap for consumer credit card 
transactions of no more than 0. 30 % of the transaction value, which are applicable to all domestic 
or cross -border  transactions. In addition, the Bank of Greece is responsible for monitoring the 
technical  and business  requirements that will apply to all categories of card -based payment 
transactions. The most significant of these  are: (i) the prohibition of territorial licensing, namely that 
licences delivered by payment card schemes for issuing or acquiring purposes should cover the 
entire Union territory ; (ii) the separation of the payment card schemes and the processing entities  
in term s of accounting, organisation and decision- making processes ; (iii) the prohibition against 
applying rules hindering or preventing co- badging two or more different payment brands or 
payment applications ; (iv) changes in respect of the application of the ‘Ho nour All Cards Rule’, 
whereby payees cannot be forced to accept all cards from a given payment card scheme;  (v) the 
prohibition against  preventing payees from steering consumers to the use of any payment 
instrument of their preference.  In addition, the Bank of Greece is responsible for monitoring rules 
which aim at increasing transparency in respect of charges applied to payees , such as : (i) the 
unblending and breakdown of the total fees charged to payees with respect to each category and 
brand of payment c ard; and (ii ) the obligation of the payment service provider to provide certain 
information relating to individual transactions to the payee . Finally , the responsibilities conferred 
upon the Bank of Greece also include the imposition of penalties on payment service providers in 
case s of infringement of the abovementioned rules . 
1.4 The draft law also designates the General Secretariat for Commerce and Consumer Protection as 
the competent authority  responsible for ensuring that consumers may obtain two or more different 
payment brands on a card- based payment instrument from a payment service provider , as well as 
for ensuring payees’ obligation to  display which cards they accept at the entrance of the ir business 
and at the till in a clear and unequivocal manner. T he General Secretariat for  Commerce and 
Consumer Protection is also empowered to impose penalties in cases  of infringement of the 
abovementioned rules.  
 
2. General o bservations  
In this opinion, t he ECB will only assess those provisions of the draft law that m ay impact on the role and 
tasks of the Bank of Greece as a national central bank  (NCB) , national supervisory authority and member 
of the Eurosystem and the European System of Central Banks (ESCB).  Consequently, this opinion will 
not address the question of  whether the draft law , if adopted as proposed,  would represent an effective 
means of implementing Regulation (EU) 2015/751 in Greece.  
 
                                                 
4  Articles 8(2) and 10(4) of Regulation (EU) 2015/751.  
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3 3. New tasks of the Bank of Greece  
3.1 The draft law expands the current supervisory functions  of the Bank of Greece,  by assign ing to it 
the responsibility for supervising interchange fees in respect of payment service providers and 
payment card schemes and other technical and business requirements relating to card- based 
payment transactions. It should be noted that the Bank of Gr eece is already the competent 
authority for supervising payment service providers pursuant to Law No 3862/20105, which 
transposed Directive 2007/64/ΕC  of the European Parliament and of the Council6, Directive 
2007/44/ΕC  of the European Parliament and of the Council7 and Commission Directive 
2010/16/ΕU8 into the Greek legal order. However, the Bank of Greece does not have any  statutory 
powers in the fields  of competition and consumer protection , nor does it  exercise any supervisory 
tasks over payment service providers or payment card schemes as regards their compliance with 
competition and consumer protection rules.  Thus, the conferral upon the Bank of Greece under the 
draft law of the power to monitor and ensure the compliance of payment service providers , 
payment card schemes and payees with their obligations under Regulation (EU) 2015/751,  and to 
impose penalties in case s of infringement  pursuant to Article 59(2) of Law No 4261/2014,  are 
considered to be new tasks  of the Bank of Greece.   
3.2 The ECB underlines that a proposed conferral of  tasks on an  NCB in the ESCB must be assessed 
against the prohibition o n monetary financing under Article 123 of the Treaty . For the purposes of 
that prohibition, Article 1(1)(b)(ii) of Council Regulation (EC) No 3603/939 defines ‘other type of 
credit facility’ as, inter alia , ‘any financing of the public sector’s obligations vis -à-vis third parties’.  
Ensuring that Member States implement a sound budgetary policy is one of the key objectives of 
the monetary financing prohibition , which may not be circumvented10. Therefore, the task of 
financing measures, which are normally the responsibility of the Member States , and which are 
financed from their budgetary sources rather than by the NCBs, must not be entrusted to NCBs. To 
decide w hat constitutes financing of the public sector’s obligations vis -à-vis third parties, which can 
be translated as the provision of central bank financing outside the scope of central bank tasks, it is 
necessary to carry out , on a case- by-case basis, an asse ssment of whether the task to be 
undertaken by an NCB is a central bank task or a government task , i.e. a task within the 
responsibility of the Member States . In other words, adequate safeguards must be in place to 
                                                 
5   Νόμος υπ’ αριθμ. 3862/2010 «Προσαρμογή της ελληνικής νομοθεσίας στις Οδηγίες 2007/64/ΕΚ, 2007/44/ΕΚ και 
2010/16/ΕΕ που αφορούν υπηρεσίες πληρωμών στην εσωτερική αγορά, προληπτική αξιολόγηση προτάσεων 
απόκτησης συμμετοχής σε επιχειρήσεις του χρηματοπιστωτικού τομέα και άλλες διατάξεις», [ΦΕΚ A/113/13.7.2010].  
6  Directive 2007/64/EC of the European Parliament and of the Council of 13 November 2007 on payment services in 
the internal market amending Directives 97/7/EC, 2002/65/EC, 2005/60/EC and 2006/48/EC and repealing Directive 
97/5/EC (OJ L 319, 5.12.2007, p. 1).  
7  Directive 2007/44/EC of the European Parliament and of the Council of 5 September 2007 amending Council 
Directive 92/49/ EEC and Directives 2002/83/EC, 2004/39/EC, 2005/68/EC and 2006/48/EC as regards procedural 
rules and evaluation criteria for the prudential assessment of acquisitions and increase of holdings in the financial 
sector (OJ L 247, 21.9.2007, p. 1).  
8   Commission Directive 2010/16/EU of 9 March 2010 amending Directive 2006/48/EC of the European Parliament and 
of the Council as regards the exclusion of a certain institution from the scope of application ( OJ L 60, 10.3.2010, 
p. 15). 
9  Council Regulation (EC) No 3603/93 of 13 December 1993 specifying definitions for the application of the 
prohibitions referred to in Articles 104 and 104b(1) of the Treaty (OJ L 332, 31.12.1993, p. 1).  
10  Article 123 of the Treaty also serves the objective of maintaining price stability and reinforces central bank 
independence.  
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4 ensure that circumventions of the objecti ve of the monetary financing prohibition of  maintaining a 
sound budgetary policy of Member States do not take place.  
3.3 As part of its discretion in the exercise of its duty , on the basis of Article 271(d) of the Treaty and 
Article 35.6 of the Statute of the European System of Central Banks and of the European Central 
Bank (hereinafter the ‘Statute of the ESCB’), to ensure that NCBs honour the obligations laid down 
by the Treaty , the Governing Council has endorsed safeguards of that kind in the form of criteri a for 
determining what may be seen as falling within the scope of a public sector ’s obligation within the 
meaning of Article 1(1)(b)(ii) of Regulation (EC) No 3603/93 or, in other words, what constitutes a 
government task as follows:  
First, central bank t asks are in particular those tasks that are related to the tasks that have been 
conferred upon the ECB and the NCBs by the Treaty and the Statute of the ESCB. These tasks are 
mainly defined in Article 127(2), (5) and (6) and Article 128(1) of the Treaty, as well as Article 22 
and Article 25.1 of the Statute of the ESCB.  
Second, Article 14.4 of the Statute of the ESCB allows NCBs to perform ‘other functions’, new 
tasks, i.e. tasks that are not related to tasks that have been conferred upon the ECB and the N CBs, 
are not precluded per se. However, new tasks that are undertaken by an NCB and which are 
atypical of NCB tasks or which are clearly discharged on behalf of and in the exclusive interest of 
the government or other public sector entities should be consi dered government tasks.  
Third, an important criterion for qualifying a new task as atypical of an NCB task or as being clearly 
discharged on behalf of and in the exclusive interest of the government  or other public sector 
entities  is the impact of the tas k on the institutional, financial and personal independence of  the 
NCB .  
In particular, the following aspects should be taken into account:  
(a) whether the performance of the new task creates conflicts of interest with existing central 
bank tasks which are not adequately addressed and does not necessarily complement those 
existing central bank tasks. If a conflict of interest arises between existing and new tasks, 
sufficient safeguards to mitigate that conflict should be in place. The complementarity 
between a new task and the existing central bank tasks should not be interpreted broadly, so 
as to lead to the creation of an indefinite chain of ancillary tasks. Such complementarity 
should also be examined in relation to the financing of those tasks;  
(b) whether with out new financial resources the performance of the new task is disproportionate 
to the NCB’s financial or organisational capacity and may have a negative impact on the 
capacity to perform properly the existing central bank tasks;  
(c) whether the performance of  the new task fits into the institutional set -up of the NCB in the 
light of central bank independence and accountability considerations;  
(d) whether the performance of the new task harbours substantial financial risks;  
(e) whether the performance of the new task exposes the members of the NCB decision- making 
bodies to political risks which are disproportionate and may also have an impact on their 
personal independence and, in particular, on the guarantee of term of office set out in 
Article  14.2 of the Statute of the ESCB.  
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5 3.4 On the basis of the criteria set out  above, the following paragraphs assess whether the new tasks 
of the Bank of Greece are in line with the monetary financing prohibition . 
3.4.1  Tasks related to the tasks conferred upon the ECB and the NCBs by the Treaty and the Statute of 
the ESCB  
The tasks conferred upo n the Bank of Greece in relation to ensuring enforcement of interchange 
fee caps  between the issuing and the acquiring banks of card- based payment instruments as well 
as compliance with the requirement s of Regulation (EU) 2015/751 by payment service providers, 
card payment schemes and payees are not among the central banking tasks listed in Article 127(2) 
and (5) of the Treaty (they have not , in other words,  been conferred upon the NCBs  under primary 
Union law). In addition, the tasks  in question appear to go beyond the scope of the existing tasks of 
the Bank of Greece as supervisory authority of payment service providers , to the extent that there 
is no Greek law empower ing the Bank of Greece to exercise supervision of payment card 
schemes, or which grants any competences  in the field s of competition and consumer protection. 
In Greece , competences in the field of competition lie with the Hellenic Competition Commission11, 
whereas competences in the field of consumer protection lie with the General Secretariat of 
Commerce and Consumer Protection12. The General Secretariat for Commerce and Consumer 
Protection is the competent authority under national law13 to receive complaints from consumers 
and impose penalti es on merchants where they violate their obligation to display which cards they 
accept at the entrance of their business and at the till in a clear and unequivocal manner . The 
conferral of  further  tasks  related to consumer protection on the General Secretariat for Commerce 
and Consumer Protection  is within the abovementioned division of competences between the 
national authorities.  
At the same time, the new  tasks complement existing supervisory tasks as the Bank of Greece 
already supervises  payment institut ions as payment service provider s. These existing supervisory 
tasks must not be viewed  in isolation from the objective of  safeguarding the smooth and efficient 
functioning of the payment system s14. In this respect, p ursuant to Law No 3862/2010,  the Bank of 
Greece is responsible for authoris ing, supervising and withdrawing the authorisation of payment 
institutions providing  payment services after assessing the ir programme of operations, business 
plan, the holding of initial capital and own funds, their governance arrangements, internal control 
mechanisms, structural organisation, and the identity of the directors and persons responsible for 
their management. In this sense, the Bank of Greece’s  new tasks could be regarded, in the 
particular context of this Regu lation,  as also related to the task conferred upon the ESCB in the 
                                                 
11  The Hellenic Competition Commission is responsible for the enforcement of Law 3959/2011 on competition (as 
amended) and Union law  on competition, applied on the basis of Articles 101 and 102 TFEU in accordance with 
Article 5 of Council Regulation (EC) No 1/2003 of 16 December 2002 on the implementation of the rules on 
competition laid down in Articles 81 and 82 of the Treaty, (OJ L 1, 4.1.2003, p. 1) .  
12  The General Secretariat for Commerce and Consumer Protection is responsible for consumer protection under 
Article 1 of Presidential Decree 147/2017 ( Οργανισμός  του Υπουργείου  Οικονομίας  και Ανάπτυξης , ΦΕΚ (Α 
192/13.12,2017)).  
13  By virtue of Article 66(3) of Law No 4446/2016 «Πτωχευτικός Κώδικας, Διοικητική Δικαιοσύνη, Τέλη- Παράβολα, 
Οικειοθελής αποκάλυψη φορολογητέας ύλης παρελθόντων ετών, Ηλεκτρονικές συναλλαγές, Τροποποιήσεις του ν. 
4270/2014 και λοιπές διατάξεις», (ΦΕΚ Α' 240/22. 12.2016).  
14   See Article 2(e) of the Statute of Bank of Greece.  
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6 fourth indent of Artic le 127(2) of the Treaty,  as well as in the fourth indent of Article 3.1 of the 
Statute of the ESCB , based on the understanding that  these tasks are ancillary to the pr omotion of 
the smooth operation of payment systems15. 
3.4.2  Tasks which are atypical of NCB tasks  
Regulation (EU) 2015/751 grants Member  States  wide discretionary power in determining the 
competent authorities which are responsible for monitoring compliance with its provisions, provided 
that the designated authorities have adequate resources for the performance of the duties 
assigned to them. A number of Member States16 have already designated their NCBs as the sole 
competent authorities to ensure compliance with t he provisions of Regulation (EU) 2017/751, while 
many  other Member States17 have allocated these tasks between their  NCBs and other public 
authorities with competences in the fields of  competition and /or consumer protection . There are 
also Member States  that have not assigned any of these tasks to their NCBs. As the majority of the 
Member States have allocated at least some of the tasks relating to the application of the 
Regulation to their NCBs, the new tasks conferred upon the Bank of Greece would thus not  be 
regarded as atypical of NCB tasks.  
In addition, the ECB has consistently expressed the view that consumer protection tasks 
discharged by an NCB may be regarded as central banking tasks provided that such task s do not 
interfere with the performance of t he NCB’s ESCB- related tasks, and to the extent that those tasks 
complement existing supervisory powers and thus contribute to the soundness of the financial 
market and the preservation of confidence in the marketplace18. Without prejudice to the  ECB’s 
expressed reservations as regards the assignment of pure competition related tasks to NCBs19, the 
new tasks assigned to the Bank of Greece by the draft law could, as further explained under 3. 4.1 
above, be regarded as ancillary to the promotion of the smooth operation of payment systems, and, 
as such, they cannot be regarded as atypical of an NCB, nor being discharged in the exclusive 
interest of the government.  
                                                 
15  See paragraph 3.1.3 of Opinion CON/2016/19 and paragraph 2.4.1 of Opinion CON/2017/2.  
16  This is the case in Bulgaria (Article 122( 2) and Articles 124 and 139 of the Law on Payment Services and Payment 
Systems),  Hungary (Article 41(19) of Law CXXXIX of 2013 on the Magyar Nemzeti Bank  and Law LXXXV of 2009), 
Lithuania (Article 62 of Law No XII-2561 of 30 June 2016 on Payments), Malta (Regulation 2 of Legal Notice 326 of 
2015), Spain (Law 18/ 2014 of 15 October 2014), and Slovenia (based on the list of competent authorities available 
on the European Commission’s website 
http://ec.europa.eu/competition/sectors/financial_services/national_competent_authorities.pdf ). 
17  This is the case in Belgium  (Article XV.18/4 of the Code of Economic Law), Croatia (Article 4 paragraphs 1, 2, 5 and 
6, and Article 6 of the Law NN 50/2016 on Implementation of EU Regulations Governing Payment Systems), Ireland 
(Regulation 6 of Statutory Instrument No 550 of 2015 and of Statutory Instrument No 292 of 2016) , Italy (Article 3 of 
legislative Decree No 218 of 15 December 2017 and Article 34- quater of the Law on payment services), Netherlands 
(Article 2(r) and  Article 5 and Annex 2 of the Administrative Order  of 17 March 2017 amending the Administrative 
Order implementing EU Regulations on Financial Markets), Poland (Article 14 of the Law on Payment Services of 19 
August 2011 (Dz.U. 2017, item 2003)), Slovakia (Article 2(3) of Law 492/2009 Coll., Law 747/2004 Coll., Article 2b of 
Law No 291/2002 Coll., Article 36(1) of Law No 80/1997 Coll., Law No 514/2003 Coll., Article 90 of Law No 492/2009 
Coll.), and the Czech Republic (based on the list of competent authori ties available on the European Commission’s 
website http://ec.europa.eu/competition/sectors/financial_services/national_competent_authorities.pdf ). 
18  See paragraphs 3.2 and 4.4 of Opinion CON/2016/34 and paragraph 2.3.2 of Opinion CON/2017/3.  
19  See paragraphs 3.3.4.1, 3.3.4.2 and 3.3.4.3.1 of Opinion CON/2016/54.  
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7 3.4.3  Extent to which performance of the new task creates conflicts of interest with existing central bank 
tasks 
While the new tasks broadly appear to be of the same nature as the supervisory tasks  of the Bank 
of Greece, conflicts of interest may arise in the course of the discharge of these new tasks . As with 
other consumer protection tasks, sufficient mitigat ion measures should be in place to ensure that in 
the event of a conflict of interest supervisory considerations prevail.  Also, the Bank of Greece 
would need to mitigate any potential conflict s of interest between its new tasks and its financial 
stability mandate by ensuring that financial stability considerations  are not compromised when 
imposing penalties for a breach of an obligation under Regulation (EU) 2015/751.  
3.4.4  Extent to which performance of the new task is disproportionate to the financial or organisational 
capacity of the Bank of Greece 
The principle of financial independence requires that Member States do not put their NCBs in a 
position where they have insufficient financial resources to carry out their ESCB -related tasks, from 
an operational and financial perspective. Furthermore, each NCB concerned should have 
additional financial and human resources at its disposal to ensure that the new tasks can be carried 
out without impacting on the NCB’s operational or financial capacity to perform its ESC B-related 
tasks. In order to ensure that the Bank of Greece has the capacity to perform its ESCB -related 
tasks, the Bank of Greece must be in a position to avail itself of the necessary resources for the 
perform ance of  its new tasks, which is also required under A rticle 13(5) of Regulation (EU) 
2015/751. For instance, the Bank of Greece will be required to impose additional reporting 
obligations on  payment service providers and payment card schemes20, and will need to allocate 
additional human resources and IT infrastructure in order to collect,  process and analyse the 
relevant data. Further costs may be incurred in the context of imposing penalties . Nevertheless, t he 
draft law does not specify the resources to be used by the Bank of Greece for the discharge of its 
new tasks, nor does it provide an estimate of the direct costs likely to be incurred  in the 
performance of these tasks . Thus, it cannot be excluded that the new tasks will impact on the 
regular budget  of the Bank of Greece. The ECB therefore notes t hat it is important that adequate 
resources are available to the Bank of Greece in order to ensure that it can properly per form its 
tasks, while maintaini ng, at all times, sufficient financial means to carry out its ESCB -related tasks 
and national  tasks and to meet its administrative and operational expenses.  
3.4.5  Extent to which performance of the new task fits into the institutional set -up of the Bank of Greece, 
in the light of central bank independence and accountability considerations  
Given the complementari ty of the new tasks with the existing tasks of the Bank of Greece, as 
further explained under section 3. 4.1 above, in particular in the field of supervision of payment 
institutions, they appear to broadly fit into the institutional set -up of the Bank of Gr eece. That said, it 
is most likely  that additional organisational units may need to be established to accommodate the 
new tasks.  Also, it should be noted that the assignment of the new tasks to the Bank of Greece 
                                                 
20  See Recital 24 of Regulation (EU) 2015/751.  
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8 deviates from the well-established national  allocation of competencies under the current legal and 
institutional framework in the fields of competition and consumer protection.  
3.4.6  Extent to which the performance of tasks harbours substantial financial risks  
In the absence of any provision in the draft  law excluding the liability of the Bank of Greece in the 
discharge of its new tasks, the Bank of Greece could potentially be held liable for damages in 
accordance with the rules of Greek law on liability  applicable to the Bank of Greece.  
3.4.7  Extent to which performance of the new task exposes members of the decision -making bodies of 
the Bank of Greece to disproportionate political risks and impacts on their personal independence  
The performance of the new tasks does not appear to expose the decision- making bodies of the 
Bank of Greece to any disproportionate political risk or to have an impact on their personal 
independence  
3.4.8  Conclusion  
Without prejudice to the ECB’s expressed reservations with regard to the assignment of pure 
competition tasks to the NCBs, t he new tasks  conferred upon the Bank of Greece could, as further 
explained under section 3. 4.1 above,  be regarded as central banking tasks based on the 
understanding that they are complementary to the Bank of Greece’s existing tasks in the area of 
supervision of payment service providers  and, ultimately , ancillary to the task of promoting the 
smooth operation of payment systems . These tasks have been conferred on many NCBs in the 
ESCB and  therefore cannot generally be regarded as  being atypical of an NCB or as being 
discharged in the exclusive interest of the government.  On the other hand, some Member States 
have chosen to allocate these tasks between their NCBs and other competent authorities . In this 
respect , it is noted that the performance of these tasks under Regulation (EU) 2015/751 requires 
expertise in the fields of competition and consumer protection, neither  of which falls within the 
exclusive competence of the Bank of Greece under Greek law.   
Additionally, i t is essential that the new tasks assigned to the Bank of Greece do not have a 
negative impact on the institutional and fi nancial independence of the Bank of Greece and do not 
adversely affect  its capacity to carry out its ESCB -related tasks or  central bank  tasks . To this end, it 
must be ensured that  the Bank of Greece can avail itself of the necessary resources for the 
performance of its new tasks.  Moreover , sufficient mitigation measures  should be in place to 
adequately address any potential conflict s of interest between the new tasks of the Bank of  Greece 
and its existing supervision and financial stability mandates.  
The ECB recommends that the Greek Ministry of Finance take the above considerations into  
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9 account in deciding on whether  to confer the new tasks on the Bank of Greece.  
 
This opinion w ill be published on the ECB’s website.  
 
 
Done at Frankfurt am Main, 15 February 2018.  
 
[signed]  
 
The President of the ECB  
Mario DRAGHI