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?

Do not do it.

Informatic security is complex and introduce an exception is not a good move.

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

Current timeline is fine & more secure. Extend-it and the next move will be to delete SCA

WHAT TYPE OF INSTITUTION OR STAKEHOLDER DO YOU REPRESENT?

consumers and consumers' associations

Name of the organization

Personal