Response to discussion Paper on the EBA’s preliminary observations on selected payment fraud data under the Payment Services Directive

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Question 1: Do you have any views on the high share of cross-border frauds in the total volume of fraud?

Statistics at TBB Bank shows that the share of cross-border fraud cases is higher than the share of domestic fraud cases

Question 2: Do you have any comments on the patters that are outlined in the chapter “patterns emerging from the selected data”?

No comment

Question 3: Do you have any potential further explanations as to why, in the specific case of the remote credit transfers, the fraud rate reported by the industry is higher for payments authenticated with SCA compared to payments that are not authenticated with SCA?

It depends on the criteria for informing and the consequences for banks. For autentication with SCA, the requirements are carried out more scrupulously and accurately, since they cause direct damage to banks

Question 4: Do you have any potential explanations why PSUs bear most of the losses due to fraud for credit transfers and cash withdrawals?

No comment

Question 5: Do you have any potential explanations why the percentage of losses borne by the PSUs substantially differs across the EEA countries?

It depends on the
-Payments traffic
- average transaction amount
- difference in income among cardholders in EEA countries

Question 6: Do you have any potential explanations why the industry has reported fraud losses as having been borne mostly or significantly by “others”?

Hides the true cause of losses and responsibility

Question 7: Do you have any views regarding the observed correlation between the value of fraud and the value of losses due to fraud between H2 2019 and H2 2020?

We do not have representative statistics for this analysis

Question 8: How do you explain the fact that the manipulation of the payer by the fraudster represents a substantial share of the fraudulent non-remote credit transfers authenticated with SCA? How is this fraud type concretely executed by the fraudsters?

No comment
We can't explain

Question 9: Do you have any views regarding the types of card payment fraud that have been reported by the industry under the category “issuance of a payment order by the fraudster”, sub-category “others”?

We do not have any views

Name of the organization

TBB pank Tallinn