Difference between the two references in Articles 23(1)(d) and 19(5)(b)

Reference to "any form of security" in Article 23(1)(d) should be construed as capturing "provision of assets for the use of collateral" referred to in Article 19(5)(b); hence, reference to "any form of security" in Article 23 does not conflict with the language of Article 19. Disclaimer: This question goes beyond matters of consistent and effective application of the regulatory framework. A Directorate General of the Commission (Directorate General Financial Stability, Financial Services and Capital Markets Union) has prepared the answer, albeit that only the Court of Justice of the European Union can provide definitive interpretations of EU legislation. This is an unofficial opinion of that Directorate General, which the European Banking Authority publishes on its behalf. The answers are not binding on the European Commission as an institution. You should be aware that the European Commission could adopt a position different from the one expressed in such Q&As, for instance in infringement proceedings or after a detailed examination of a specific case or on the basis of any new legal or factual elements that may have been brought to its attention.