Response to public hearing on the Consultation paper on the amendment of the RTS on SCA&CSC under PSD2
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For details on Tink's position, we would like to refer to the ETPPA's response to the EBA's consultation on the RTS, which we endorse in its entirety.
For details on Tink's position, we would like to refer to the ETPPA's response to the EBA's consultation on the RTS, which we endorse in its entirety.
For details on Tink's position, we would like to refer to the ETPPA's response to the EBA's consultation on the RTS, which we endorse in its entirety.
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?
Thank you for considering the amendments for the RTS and recognising the challenges that AISPs are facing. We appreciate the EBA’s proposal for mandatory exemption but there is more to be considered.For details on Tink's position, we would like to refer to the ETPPA's response to the EBA's consultation on the RTS, which we endorse in its entirety.
Q2. Do you have any comments on the proposal to extend the timeline for the renewal of SCA to 180-days?
We welcome the extended timeline proposed by the EBA. We believe that any effort that contributes to the value created for both consumers and businesses is appreciated by the TPP community. We believe the EBA should also consider alternative amendments to the RTS.For details on Tink's position, we would like to refer to the ETPPA's response to the EBA's consultation on the RTS, which we endorse in its entirety.
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?
For the past two years AISPs and PISPs have been operated in a suboptimal situation for the provision of services. We believe that the changes proposed by the EBA in said consultation paper can be realised within a 3-month implementation timeline.For details on Tink's position, we would like to refer to the ETPPA's response to the EBA's consultation on the RTS, which we endorse in its entirety.