Response to public hearing on the Consultation paper on the amendment of the RTS on SCA&CSC under PSD2

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Q1. Do you have any comments on the proposal to introduce a new mandatory exemption for the case when the information is accessed through an AISP and the proposed amendments to Article 10 exemption?

I would particularly like to see strong authentication (two-stage or otherwise) as the rule for all applications, and especially for banking applications. I would like this to be done in a framework that would concern any connection without taking into account a previous connection that occurred one day, one week or one month before. This is certainly restrictive, but the security of our authentications depends on it.

Q2. Do you have any comments on the proposal to extend the timeline for the renewal of SCA to 180-days?

I absolutely do not want this proposal to succeed. I am even in favour of systematic strong authentication.

Q3. Do you have any comments on the proposed 6-month implementation timeline, and the requirement for ASPSPs to make available the relevant changes to the technical specifications of their interfaces not less than one month before such changes are required to be implemented?

I absolutely do not want this proposal to succeed. I am even in favour of systematic strong authentication.

WHAT TYPE OF INSTITUTION OR STAKEHOLDER DO YOU REPRESENT?

other - please specify

Please specify, if you selected "other type of institution"

Banking Services (as a customer)

Name of the organization

Bankin'