Submission #589

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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? Yes.

Q2. Do you have any comments on the proposal to extend the timeline for the renewal of SCA to 180-days? Yes and I want it to be extended to 365 days minimum.

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? Yes TPP can do it in under 1 month and banks should do it in under 3 months.

WHAT TYPE OF INSTITUTION OR STAKEHOLDER DO YOU REPRESENT? consumers and consumers' associations

Name of the organization Unknown