Response to public hearing on the Consultation paper on the amendment of the RTS on SCA&CSC under PSD2 | European Banking Authority
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Response to public hearing on the Consultation paper on the amendment of the RTS on SCA&CSC under PSD2
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?
We do agree with this proposal
Q2. Do you have any comments on the proposal to extend the timeline for the renewal of SCA to 180-days?
We are the B2B client of a TPP: collecting banking data through AISP’s services is critical to us in order to provide our services to our customers (who are consumers and small/medium businesses). Our customers/consumers therefore need us to continuously gather their data live without their constant intervention. We do agree that the timeline to renew SCA must be extended, and we think this extension should be way longer than the 180 days proposed
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?
NA
WHAT TYPE OF INSTITUTION OR STAKEHOLDER DO YOU REPRESENT?
