Submission #7

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WebPKI.org

Question 1: Do you consider the objectives of the RTS as identified by the EBA to be appropriate and complete? If not, please provide your reasoning.

The directive conflate Payments as a part of Banking and consumer Payments. The latter needs entirely different APIs.
https://github.com/cyberphone/saturn/blob/master/PSD2.md#purpose-of-psd2

Question 2: Do you agree with the proposed framework for cooperation and the standardised forms specified in Articles 2 to 8 and Annexes 1 to 4? If not, what other ways of cooperation would you consider more efficient? No opinion

Question 3: Do you agree with the proposed framework for notifications of infringements and suspected infringements specified in Article 8 and Annex 4? If not, how should this be done? No opinion

Question 4: Do you consider that the approach proposed in Article 10, which gives the host CA discretion to require reporting either from all payment institutions or a characteristic subset thereof, is methodologically robust? No opinion

Question 5: Do you consider that payment institutions will be able to report the data specified in Article 10 and Annex 5? If not, what obstacles do you see and how could these obstacles be overcome? No opinion

Question 6: Do you consider that payment institutions should and will be able to report the data specified in Article 11 and Annex 6? If not, what obstacles do you see and how could these obstacles be overcome? No opinion

Please select which category best describes you and/or your organisation [Other "]"

If you selected "Other", please provide details Technloogy Provider/Developer

Name of organisation WebPKI.org