ECB -PUBLIC  
 
OPINION OF THE EUROPEAN CENTRAL BANK  
of 31 May 2019  
on reform of the banking and financial market supervisory regime  
(CON/ 2019/21) 
 
Introduction and legal basis  
On 15 April 2019 the European Central Bank (ECB) received a request from the Austrian Ministry of 
Finance (MoF) for an opinion on a draft law reform ing the banking supervisory regime (hereinafter the 
‘draft law’)1. 
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 (TFEU) and on the third, fourth and sixth indent s of Article 2(1) of 
Council Decision 98/415/EC2
, as the draft law relates to the Oesterreichische Nationalbank (OeNB) , the 
collectio n, compilation and distribution of monetary, financial and banking statistics, and the rules 
applicable to financial institutions insofar as they materially influence the stability of financial institutions  
and markets , as well as the specific tasks conferred upon the ECB pursuant to Article 127(6) of the TFEU 
concerning policies relating to the prudential supervision of credit institutions. In accordance with the first 
sentence of Article 17.5 of the Rules of Procedure of the European Central Bank, t he Governing Council 
has adopted this opinion.  
 
1. Purpose of the draft law  
1.1 The draft law proposes a reform of the structure of the banking and financial market supervis ory 
regime in Austria.  According to the  explanatory memorandum, the draft law  aims to make the 
national system of financial market supervision more efficient, accelerate and simplify decision -
making processes, establish clear contacts for market participants and EU institutions , and 
increase the focus on service.  It is intended to end the current split of competenc es between the 
Austrian Financial Market Authority (FMA) and the OeNB , and to concentrate  the full extent of  
microprudential supervision in the FMA. The reform is proposed to take effect from  1 January 2020.  
The draft law does not purport to affect the OeNB’s current tasks in relation to macroprudential 
                                                 
1 Bundesgesetz, mit dem das Alternative Investmentfonds Manager -Gesetz, das Bankwesengesetz, das Betriebliche 
Mitarbeiter - und Selbständigenvorsorgegesetz, das Bundesgesetz zur Schaffung einer Abbaueinheit, das E -
Geldgesetz 2010, das Einlagensicherungs - und Anlegerentschädigungsgesetz, das Finanzkonglomerategesetz, das 
Finanzmarktaufsichtsbehördengesetz, das Investmentfondsgesetz 2011, das Nationalbankgeset z 1984, das Sani e-
rungs - und Abwicklungsgesetz, das Sparkassengesetz, STS -Verbriefungsvollzugsgesetz, das Versicherungsauf-
sichtsgesetz 2016, das Wertpapieraufsichtsgesetz 2018, das Zahlungsdienstegesetz 2018, das Zentrale Gegenpar-
teien- Vollzugsgesetz sowie das Zentralverwahrer -Vollzugsgesetz geändert werden.  
2 Council Decision 98/415/EC of 29 June 1998 on the consultation of the European Central Bank by national author i-
ties regarding draft legislative provisions (OJ L 189, 3.7.1998, p. 42).  
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2 supervision, the oversight of financial market stability and payment systems , and the collection of 
statistics.  
1.2 The draft law transfers the OeNB ’s current competenc es in relation to microprudential banking 
supervision, in particular the conduct of on- site inspections and off-site analysis  of individual banks , 
to the FMA. The same transfer  of competenc es is envisaged with regard to the supervision of 
deposit guarantee schemes and the recovery and resolution of credit institutions . Furthermore, the 
task of provid ing expert opinions  to the FMA , for example before granting a banking licence or 
approving a merger or demerger of credit institutions , is removed from the OeNB . Only the OeNB’s  
competence to implement supervisory reporting will remain unchanged.  
1.3 As a consequence of concentrating prudential supervisory tasks in the FMA, the OeNB’s 
employees whose work relates to prudential banking supervision will, where possible, be 
transferred to the FMA. It is envisaged that  employees  of the OeNB recruited after 30 April 1998  
will become employees  of the FMA from 1 January 2020 and all of their existing rights and 
obligations  will continue . OeNB internal staff rules app licable to such  employees will continue to 
apply , while  the right of the OeNB’s General Council to amend tho se rules will be transferred to the 
FMA’s Executive Board. Under  Austrian labour law, employees  may be  transferred either by way of 
secondment or by assumption  of their contracts by operation of law . Employees who joined the 
OeNB before 1 May 1998 are to be seconded to the FMA because assumption of their contracts 
would, according to the explanatory memorandum, represent a particular intrusion  into the 
employment relationship. Although such  seconded employees  are to remain employees  of the 
OeNB , the y will be integrated into the FMA’s operational services. Pursuant  to the draft law, the 
FMA will reimburse the OeNB for the payroll costs of seconded staff . 
1.4 The explanatory memorandum  accompanying the draft law states  that the OeNB’s role regarding 
macroprudential supervision and financial market stability is to remain unchanged.  The OeNB will 
remain competent to oversee financial market stability. It is intended that the OeNB will continue to 
monitor  and analyse all circumstances that are relevant to financial market stability and inform the 
MoF and FMA thereof. In addition to this current competence, the OeNB shall  in the future also 
focus on the development potential of the domestic financial market. The draft law provides for an 
increase in the number of OeNB’s representatives on the Financial Market Stability Board (FMSB) 
from one to two.  Pursuant  to the draft law , the OeNB will submit  to each of the MoF, the FMA, the 
National Council of the Austrian Parliament, the FMS B and the  new FMA Advisory Board an annual 
report on the fundamental findings of its monitoring of developments in the financial markets and 
the potential impact of those findings on the national financial market. The OeNB will set up an 
internal organisational unit  for the monitoring of developments in the financial markets . The OeNB 
will, however,  no longer have its curr ent competenc e to carry out on- site inspections for 
macroeconomic reasons , and will only have the ability to instruct the FMA to conduct such on-site 
inspections for reasons of financial market stability, for macroeconomic reasons , or in a crisis 
situation. The OeNB must state the reasons for the inspection and specify  its intended scope. The 
FMA may either comply with the inspection  instruction,  or refuse it and state the reasons for the  
refusal.  The FMA may only refuse to conduct an audit if it would compromise the audits included in 
the FMA’s inspection  programme or other FMA inspections , or if the data requested in the 
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3 inspection instruction are already accessible to the OeNB or  can immediately be made accessible.  
If the OeNB considers that there is an imminent risk, the FMA may not refuse the inspection  
instruction and must comply with it immediately3
. 
1.5 The draft law requires the OeNB and the FMA to continue exchanging reporting data, statistical 
information and all other data and information necessary to accomplish their respective tasks in a 
suitable and efficient manner . For this purpose the FMA and the OeNB are required to conclude a 
bilateral memorandum of understanding which must be published and set out details of the ir 
collaboration and the information flow between them. Further memoranda  of understanding will 
regulate the conduct of on -site inspections by the FMA if instructed by the Oe NB, as well as  the 
transfer of employees  from the OeNB to the FMA and vice versa. More extensive information 
obligations are to be established in times of crisis in order to ensure effective collaboration.  
1.6 The draft law provides for a number of changes to the FMA’s governance structure.  Among other 
things, t he FMA will establish a Financial Market Advisory Board, whose role will be to advise the 
FMA on financial market matters, monitor and analyse international trends on the financial markets, 
and propose s upervisory priorities. The Financial Market Advisory Board will have powers to adopt 
and publish opinions and recommendations. Its members will be appointed by the MoF for a five-
year term and will perform their duties in an honorary capacity. Members will  be nominated by 
various ministries, the Austrian Chamber of Commerce, the Vienna Stock Exchange, the OeNB 
and the Oesterreichische Kontrollbank. The business of the Financial Market Advisory Board will 
be administered by the FMA, and its rules of procedur e will be established by the MoF.  
1.7 The draft law proposes an increase in the amount of profits to be distributed by the OeNB to its 
sole shareholder, the Austrian Federation,  from 90 to 95 per cent. The explanatory memorandum  
explains that the increase is due to the transfer of competence for on-site inspections and 
microprudential analysis to the FMA.  Currently, the OeNB’s costs of carrying out prudential 
supervisory tasks are partly refunded to it by the FMA , up to a statutory maximum annually of EUR 
11 million , and the balance is  borne  by the OeNB ( in 2018 , for example, the balance amounted to 
EUR 42.6 million).  The impact assessment of the draft law calculates that from 2020 annual costs 
previously incurred by the OeNB  in carrying out prudential supervisory  tasks in the amount of EUR 
39.6 million will no longer be incurred once the competences are transferred – taking into account 
synergy effects and increased savings potential . Accordingly, the MoF concludes that  these cost 
savings would become available for annual distribution to the Austrian Federation,  in addition to the 
share of the profit that is currently distributed . According to the impact assessment, the MoF 
expects an increase in profit distribution of EU R 38.5 million per year from 2020 until 2023.  
1.8 As the Austrian authorities do not intend to increase the supervisory fees to be paid by supervised 
entities , the increased costs incurred by the FMA due to the transfer of prudential supervisory tasks 
from the OeNB to the FMA  will need to be funded by the Austrian Federation . According to t he 
MoF’s calculat ions,  these costs will amount to EUR 33 million annually . Moreover , due to an 
                                                 
3 See the proposed amendment to Section 70 paragraph 1c of the Law on banking ( Bankwesengesetz ), contained in 
the draft law.  
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4 extended regulatory role of the FMA, it is expected that the annual costs of the MoF itself will 
increase by EUR 4.5 million.  
1.9 The draft law clarifies the significant contribution of the OeNB to  financial education and literacy. In 
particular, it provides that the OeNB will send the MoF an annual report on fundam ental findings on 
the status of financial education in Austria.  
1.10 Lastly, the explanatory memorandum to the draft law envisages a stronger separat ion between 
regulation and supervision than currently exists , thereby strengthening the role of the MoF  in the 
field of regulation. For this purpose, three new departments with 30 new staff will be established in 
the division of the MoF  that deals with financial markets .  
 
2. Observations  
2.1 Distribution of the OeNB’s profits  
2.1.1  In order to ensure financial independence, the national central banks (NCB s) must always have 
sufficient resources to carry out their  tasks related to the European System of Central Banks 
(ESCB), as well as  their national tasks4
. Member Stat es may not put their NCBs in a position where 
they have insufficient financial resources and inadequate net equity to carry out their tasks5
. An 
NCB ’s overall independence would be jeopardised if it could not autonomously avail itself of 
sufficient financial resources to fulfil its mandate.  
2.1.2  In accordance with the current national law, certain amounts must  be deducted from the OeNB’s 
operating profit  prior to profit  appropriation:  namely , earnings from assets in which the pension 
reserve has been invested;  interest credited to the temporary reserve account for loans extended 
by the OeNB under the E uropean Recovery Programme ; and earnings from assets in which the 
Fund for the Promotion of Scientific Research and Teaching set up by the OeNB has invested. 
Furthermore, before making any profit appropriation, up to 10 per  cent of the annual profit that 
remains  after deduct ing the amounts  referred to above must  be transferred, if necessary,  to the 
OeNB’s pension reserve until  it reaches the level at which it is  adequately funded – according to 
actuarial calculations  – in order to meet the current pension claims of the beneficiaries . If, however,  
the pension reserve is significantly overfunded, the excess  must be released and accounted for in 
the profit and loss account. After account ing for  the deductions  from the operating profit  as referred 
to above, the OeNB is obliged under the current national law to distribute 90 per  cent of the 
balance of the profit to the Austrian Federation. Further,  after such distribution, a dividend of up to 
10 per  cent of the share capital  of the Austrian Federation in the OeNB  must  be paid out to the 
Austrian Federation, by decision of a general meeting of the OeNB . The profit then remaining (the 
‘remaining profit’) is requi red to be appropriated in accordance with a decision of a general meeting 
of the OeNB . The ECB understands that the draft law provides for an increase,  from 90 to 95 per 
cent, of the proportion of the OeNB’s profit  – after the deductions from operating profit as referred 
                                                 
4 See, e.g., paragraph 3.5 of Opinion CON/2016/45. All ECB opinions are published on the ECB’s website at 
www.ecb.europa.eu.  
5 See, e.g., paragraph 3.1.1 of Opinion CON/2016/4 (with specific reference to Austria).  
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5 to above, and before payment of the dividend – that is  to be distri buted in future to the Austrian 
Federation.  
2.1.3  An NCB’s statute may prescribe how its profits are to be allocated6
. Profits may be distr ibuted to 
the State budget only after any accumulated losses from previous years have been covered7
 and 
after financial provisions deemed necessary to safeguard the real value of the NCB’s capital and 
assets have been created8. Member States may not hamper NCBs in  building up their reserve 
capital to a level which is necessary for a member of the ESCB to fulfil its tasks9
. The ECB stresses 
the importance of  the OeNB ’s ability to independently create and adequately build up reserves  and 
provisions . Under Austrian law10
, the OeNB is obliged to prepare its balance sheet and its profit 
and loss account in conformity with the rules established by the Governing Council of the ECB 
under Article 26.4 of the Statute of the ESCB and of  the ECB. Consequently, the OeNB has 
adopted the ESCB’s accounting rules11
 and applies them in their entirety to its financial statements.  
However, the remaining profit is the only means by which the OeNB can increase its reserve 
serving as a general risk provision. Hence the proposed increase of the proportion of the OeNB’s 
profit to be distributed to the Austrian Federation limits the OeNB’s ability to adequately build  up 
this reserve.  
2.1.4  In any event , any amendment to the profit distribution rules of an NCB should only be initiated and 
decided in close cooperation with th at NCB, since the NCB  is in the best position to assess its 
required level of reserve capital12
. With a view to  ensuring financial indep endence, the ECB 
requests that a decision by the consulting authority on the intended amendment to the profit 
distribution rules of the OeNB be taken only in cooperation with the OeNB.   
2.1.5  Furthermore, the ECB understands that the increased profit distribution to be made by the OeNB is  
intended to compensate the Austrian Federation for the increased supervisory costs  that the latter 
will incur , both within the MoF and at the FMA. However, as 90 per  cent of the remaining profit s are 
already distributed to the Austrian Federation under the current regime, the cost savings envisaged 
at the level of the OeNB would, in any event,  lead to an increase in profit  and in the corporate 
income tax charge.  Thus, the proposed increase in the profit distribution percentage would not be 
necessary to achieve  an increased profit distribution by the OeNB.  
2.2 The OeNB’s role regarding financial market stability  and macroprudential supervision  
2.2.1  Consistent ly with Article 127(5) of the T FEU, the ECB has repeatedly noted the important  role of 
                                                 
6 See ECB Convergence Report 2018, p. 27. In the absence of such provisions, decisions on the allocation of profits 
should be taken by the NCB ’s decision- making bodies on professional grounds, and should not be subject to the di s-
cretion of third parties, unless there is an express safeguard clause stating that this is without prejudice to the finan-
cial means necessary for carrying out the NCB’s ESCB- related tasks as well as national tasks (see, e.g., paragraph 
2.3 of Opinion CON/2017/17).  
7 See paragraph 4.3 of Opinion CON 2009/85 and paragraph 3.2.5 of Opinion CON/2017/17.  
8 See ECB Convergence Report 2018, p. 27.  
9 See paragraph 3.3 of Opinion CON/2009/26 and paragraph 2.1 of Opinion CON/2012/69.  
10 See section 67 paragraph 2 of the Law on the National Bank.  
11 Guideline (EU) 2016/2249 of the European Central Bank of 3 November 2016 on the legal framework for accounting 
and financial reporting in the European System of Central Banks (ECB/2016/34) (OJ L 347, 20.12.2016).  
12 See ECB Convergence Report 2018, p. 27, paragraph 3.3 of Opinion CON/2009/53 and paragraph 3.6. of Opinion 
CON/2009/83.  
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6 NCBs in prudential supervision to allow the Eurosystem to contribute adequately to monitoring the 
risks to financial stability in the euro area13
. At the same time, the draft law does not seek to affect  
the OeNB’s existing role regarding macroprudential supervision, the oversight of  financial market 
stability and payment systems, supervisory reporting,  and the collection of statistics. While the draft 
law withdraws the OeNB’s current competenc e to carry out on- site inspections , it authorises the 
OeNB to instruct the FMA to conduct on- site inspections for reasons of financial market stability, or  
macroeconomic reasons , or in a crisis situation , and the FMA must comply with the OeNB’s 
inspection instruction immediately if the OeNB considers that there is an imminent risk . It is for the 
Austrian authorities to assess whether the withdrawal of the OeNB’s current competence for  
carry ing out on- site inspections for macroeconomic reasons complies with A ustrian constitutional 
principles. Underlining the OeNB’s role regarding oversight of financial market stability , the draft 
law increases the number of the OeNB’s representatives in the FMSB from one to two. In addition, 
the OeNB is to  nominate two of the six members of the FMA’s Supervisory Board and one member 
of the FMA’s Financial Market Advisory Board. All of these mechanisms should help to ensure that 
the transfer of prudential supervisory tasks from the OeNB to the FMA does not j eopardise the 
OeNB’s ability to safeguard financial stability and prevent or mitigate systemic risks.  In order to 
safeguard the OeNB’s remaining tasks and functions, in particular macroprudential supervision and 
oversight of financial market stability, the ECB additionally recommends that the OeNB is provided 
with access to all relevant information necessary for its ongoing tasks14
. 
2.3 The FMA’s tasks within the S ingle Supervisory Mechanism  
2.3.1  Pursuant to Article 127(6) of the T FEU and Article s 4 and 6 of Council Regulation (EU) No 
1024/201315, the ECB is responsible for the effective and consistent functioning of the SSM, and 
the ECB and the NCAs are each subject to a duty of cooperation, and an obligation to exchange 
information.  Where appropriate , and without prejudice to the responsibility and accountability of the 
ECB for the tasks conferred on it by Regulation (EU) No 1024/2013, the NCAs are responsible for 
providing assist ance to  the ECB, on the terms set out in Regulation (EU) No 468/2014 of the 
European Cent ral Bank (ECB/2014/17)16
, with the preparation and implementation of any acts 
relating to the tasks conferred on the ECB under Article 4 of Regulation (EU) No 1024/201317 
related to all credit institutions, including assistance in verification activities18. 
                                                 
13 See paragraph 2 of Opinion CON/2013/56.  
14  See paragraphs II.b) to e) of the OeNB’s opinion on  the draft law , dated 7 May 2019, which is published on the Aus-
trian Parliament’s website at www.parlament.gv.at .. 
15 Council Regulation (EU) No 1024/2013 of 15 October 2013 conferring specific tasks on the European Central Bank 
concerning policies relating to the prudential s upervision of credit institutions (OJ L 287, 29.10.2013, p. 63).  
16  Regulation (EU) No 468/2014 of the European Central Bank of 16 April 2014 establishing the framework for coop-
eration within the Single Supervisory Mechanism between the European Central Bank and national competent au-
thorities and with national designated authorities (SSM Framework Regulation) (OJ L 141, 14.5.2014, p. 1).  
17 See paragraph 2.2 of Opinion CON/2018/6 and paragraph 2.4 of Opinion CON/2016/43.  
18  Without prejudice to certain provi sions of Regulation (EU) No 1024/2013, NCAs shall carry out and be responsible 
for certain tasks and adopting all relevant supervisory decisions with regard to certain less significant credit instit u-
tions or financial holding companies. Wherever the ECB is  assisted by NCAs for the purpose of exercising the tasks 
conferred on it by Regulation (EU) No 1024/2013, the ECB and the NCAs shall comply with the provisions set out in 
the relevant Union acts in relation to the allocation of responsibilities and cooper ation between competent authorities 
from different Member States.  
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7 2.3.2  Taking into account the responsibilities of the FMA within the framework of the SSM, the ECB 
notes that Article 4(4) of Directive 2013/36/EU of the European Parliament and of the Council19 
requires Member States to ensure that the competent authorities have the expertise, resources, 
operational capacity, powers and independence necessary to carry out the functions relating to 
prudential supervision, investigations and penalties set out in that  Directive and in Regulation (EU) 
No 575/2013  of the European Parl iament and of the Council20
. According to the recommendation of 
Basel Core Principles for Effective Banking Supervision the supervisor is to have adequate 
resources for the conduct of effective supervision and oversight21
. 
2.3.3  The ECB recommends that the Austrian authorities clarify in the draft law  that the Financial Market 
Advisory Board, which includes industry representatives and representatives of supervised entities 
in matters of banking supervision, will not obtain any confidential information,  and that any such 
information shared in the SSM will not be  provided to the Financial Market Advisory Board.  
Regarding the operational independence of the FMA , the ECB  highlights Article 19 of Council 
Regulation (EU) No 1024/2013,  which provides that the members of the ECB ’s Supervisory Board 
must act independently and objectively in the interest of the Union as a whole and must neither 
seek nor take instructions from the institutions or bodies of the Union, from any government of a 
Member State or from an y other public or private body.  
2.3.4  Furthermore, the OeNB’s Governor , acting in his  or her  personal capacity,  participates in decisions 
adopted by the ECB’s Governing Council on supervisory matters relating to the SSM , mainly based 
on complete draft decisions  proposed by the ECB ’s Supervisory Board pursuant to the non-
objection procedure specified under Article 26(8) of Council Regulation (EU) No 1024/2013. As for 
all his or her tasks , concerning SSM matters , the Governor needs to have the necessary resources 
as well as access to relevant information and data.  In this respect , attention should be paid to the 
OeNB’s ability to employ and retain qualified  staff necessary in view of  its autonomy in staff matters 
deriv ing from its financial independence22
. 
2.4 The OeNB’s role regarding financial education  
2.4.1  Regarding the prohibition o n monetary financing under Article 123 of the T FEU, as supplemented 
by Council Regulation (EC) No 3603/93, t he ECB notes that, inter alia, any financing by a central 
bank of the public sector’s obligations vis -à-vis third parties  is prohibited . Accordingly, national 
legislation may not require an NCB to finance either the performance of functions by other public 
sector bodies , or the public sector’s obligations vis -à-vis third par ties. This prohibition applies in the 
                                                 
19  Directive 2013/36/EU of the European Parliament and of the Council of 26 June 2013 on access to the activity of 
credit institutions and the prudential supervision of credit institutions and investment firms, amending Directive 
2002/87/EC and repealing Directives 2006/48/EC and 2006/49/EC  (OJ L 176, 27.6.2013, p. 338).  
20  Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requir e-
ments for  credit institutions and investment firms and amending Regulation (EU) No 648/2012 (OJ L 176, 27.6.2013, 
p. 1). 
21 According to the Basel Core Principles for Effective Banking Supervision, the head of a supervisory authority is also 
to be appointed for a minimum term and removed from office during that term only for reasons specified in law, or if 
not physically or mentally capable of carrying out the role, or if found guilty of misconduct.  See Basel Committee on 
Banking Supervision, Core Principles for Ef fective Banking Supervision (September 2012), Principle 2, Effective Cr i-
teria 2 and 6, available on the website of the Bank for International Settlements at www.bis.org . 
22 See ECB Convergence Report May 2018, p. 28.  
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8 case of  conferral of new tasks upon NCBs23
. However, the ECB understands that the OeNB 
already provides financial education to the Austrian population, promotes a general understanding 
of economic interrelationships, and organises a wide range of educational opportunities24
. Hence, 
the draft law only serves to clarif y the OeNB’s role in connection with financial literacy, by explicitly 
providing that it will also contribute to the development of financial training in Aust ria, including by 
submitting to the MoF an annual report on fundamental findings on the status of financial education 
in Austria25
. On that basis, the ECB considers th at the draft law does  not confer a new task on the 
OeNB in the context of providing financial education.  
2.4.2  As previously noted by the ECB, financial education is not among central banking tasks listed in the 
Treaties26
. Nevertheless, the tasks carried out by the OeNB in the area of financial education could 
be considered as complementary to the macroprudential - and financial market stability -related 
tasks that it currently perform s. Furthermore, they do not appear to be atypical for NCBs of the 
ESCB27
. However, ensuring the provision of general financial education forms part of the 
educational  policies  of the State. In this respect, these tasks will be administered,  at least in part , 
on behalf of and in the interest of the government.  
2.4.3  Regarding financial independence, t he ECB reiterates that an NCB needs to have available to it  
sufficient financial resources to fulfil its mandate, i.e. to perform its  ESCB- related tasks and its 
national tasks. The consulting authority must  take into consideration that the OeNB should have  
sufficient resources available for the performance of its tasks. T he ECB understands that the OeNB 
will be in a position to carry out these tasks without a negative impact on its core central bank ing 
tasks . 
 
This opinion will be published on the ECB’s website.  
 
 
Done at Frankfurt am Main, 3 1 May  2019 . 
 
[signed]  
 
The President of the ECB  
Mario DRAGHI  
 
                                                 
23 See ECB Convergence Report 2018, p. 30.  
24 For example, the OeNB provides tailor -made offers regarding financial education on its financial education online 
platform. According to its website, the OeNB is constantly striving to expand and improve these opportunities.  
25 See the proposed amendment to section 44b paragraph 5 of the Law on the National Bank ( Nationalbankgesetz ), as 
included in the draft law.  
26  See paragraph 3.4 of Opinion CON/2017/43  and paragraph 4.2 of Opinion CON/2018/2.  
27  See paragraph 3.2 of  Opinion CON/2017/43 .