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?

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 BTOC business and our customers need to be always connected to there bank account. 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. In our opinion, this timeline should be ideally more than one year. On one hand, our customers simply do not understand why they are being asked to renew their SCA and often complain to us that they do not feel the need or the use for it.

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?

other - please specify

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

We are an Asset Management Company with a dedicated mobile app used by our customers to invest in financial markets

Name of the organization

Wide Asset Management