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?


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

YES but I would much prefer a timeline extended to 365-Days

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?

Do not understand why it should take so much time. Third Party Provider should be able to do it in 1 month and banks can do it in in under 3 months with enough pressure.
In any correctly developed system the timeline for the renewal od SCA must be a parameter, so easy to change.


consumers and consumers' associations

Name of the organization

Vincent Herlicq