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?

//ABANCA is of the view that leveling the playing field and reducing customer friction is the way to foster innovation in the payments landscape. We are committed to supporting any initiative on new financial products or services as we strongly believe that this will enhance our customers overall experience and satisfaction.

Following that principle, and performing the mandatory risk analysis, we apply all possible exemptions in our dedicated interface for both AISPs and PISPs, the same way we do in the interfaces we offer directly to our customers. That includes the 90 days period for SCA renewal as stated in the PSD2 directive.

Taking that into account, introducing the exemption as mandatory will have no impact on our current implementation. Nevertheless, it would imply an actual change on the relationship with the TPPs, as that will put them in position to demand the exemption in any future circumstances.

//ABANCA is strongly committed to gain and maintain customers' trust and one of the ways to achieve it is to offer solid support. We do our best to provide intuitive applications that cover all user needs and give communication channels to answer any possible questions and assist on any possible problem.

The confidence of our customers may be undermined when //ABANCA cannot offer a proper solution for a customer problem inside its own channels. And that is the case when a client contacts us to revoke a TPP consent and, according to PSD2, we have to instruct them to contact the TPP directly, outside our channels.

The customer’s perception of the inability of the ASPSP to perform that kind of actions may decrease the credibility of the bank as custodian of the credentials and protector against fraud and that may become an obstacle to the adoption of new products and services offered by TPPs or the ASPSP itself

Therefore, is the view of //ABANCA that the mandatory exemption should be accompanied by counterpart measures to keep the leveling field principle. Namely, we encourage to study the possibility of giving the PSU a way to revoke the consent via the ASPSP`s channels. We believe what would lower the barrier of the customer’s lack of confidence on new applications.

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

//ABANCA is of the view that limited account information, as proposed in the exemption, has a low chance of being object of fraud, so with the proper risk analysis, a 180-day period without SCA should not be a problem from the point of view of fraud management.

Nevertheless, we are concerned about the side effects of a six month period of non-SCA non-revocable access granted to a TPP. Namely, and apart from the arguments exposed in the Q1 answer, we think there may be an increase of the frequency of transactions retrieval, that could potentially affect the performance of the dedicated interface or the ASPSPs channels.

To level the playing field, and in exchange for the extension of the duration of the exemption, measures like limiting the number or frequency of requests could be studied and implemented

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?

//ABANCA has no specific comments on these deadlines, as long as they apply only for new consents. It is quite simple for us to extend the duration of the new SCA consents, but we think that current SCAs expiration date should be preserved as that was the conditions the user agreed to when accepted


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