Response to consultation on draft Guidelines on the limited network exclusion under PSD2
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2.1 (c) The "size" of the geographic is not pertaining in respect of PSD2 Art. 3(k)(i)
2.2 (a) The "size" of the geographic is subjective and not objective
2.2 (b) the volume of payment transaction should be indicated
If no value is given for all the art. 2.2 items, all the evaluations could be subjective and not objective.
Q1. Do you have comments on Guideline 1 on the specific payment instruments under Article 3(k) of PSD2?
1.4- If the meaning of "user" is related to the merchant accepting the payment instrument the article is clear otherwise it should be explainedQ2. Do you have comments on Guideline 2 on the limited network of service providers under Article 3(k)(i) of PSD2?
2.1 (b) The maximum number of providers should be indicated2.1 (c) The "size" of the geographic is not pertaining in respect of PSD2 Art. 3(k)(i)
2.2 (a) The "size" of the geographic is subjective and not objective
2.2 (b) the volume of payment transaction should be indicated
If no value is given for all the art. 2.2 items, all the evaluations could be subjective and not objective.