Submission #44

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JACCOO

Question 1: Do you agree with the EBA’s reasoning on the requirements of the strong customer authentication, and the resultant provisions proposed in Chapter 1 of the draft RTS? Yes.

Question 2: In particular, in relation to the “dynamic linking” procedure, do you agree with the EBA’s reasoning that the requirements should remain neutral as to when the “dynamic linking” should take place, under the conditions that the channel, mobile application, or device where the information about the amount and the payee of the transaction is displayed is independent or segregated from the channel, mobile application or device used for initiating the payment, as foreseen in Article 2.2 of the draft RTS. Yes.

Question 3: In particular, in relation to the protection of authentication elements, are you aware of other threats than the ones identified in articles 3, 4 and 5 of the draft RTS against which authentication elements should be resistant? No.

Question 4: Do you agree with the EBA’s reasoning on the exemptions from the application of Article 97 on strong customer authentication and on security measures, and the resultant provisions proposed in Chapter 2 of the draft RTS? Yes.

Question 5: Do you have any concern with the list of exemptions contained in Chapter 2 of the draft RTS for the scenario that PSPs are prevented from implementing SCA on transactions that meet the criteria for exemption? No.

Question 6: Do you agree with the EBA’s reasoning on the protection of the confidentiality and the integrity of the payment service users’ personalised security credentials, and the resultant provisions proposed in Chapter 3 of the draft RTS? Yes.

Question 7: Do you agree with the EBA’s reasoning on the requirements for common and secure open standards of communication for the purpose of identification, authentication, notification, and information, and the resultant provisions proposed in Chapter 4 of the draft RTS? Yes.

Question 8: In particular, do you agree that the use of ISO 20022 elements, components or approved message definitions, if available, should be required to ensure the interoperability of different technological communication solutions implemented between PSPs for the provision of AIS, PIS or for the confirmation on the availability of funds? Do you see any particular technical constraint that would prevent the use of such industry standards?

Yes, although xml-type messages are considerably larger than column record-type messages. May we suggest JSON as an alternative?

Question 9: With regards to identification between PSPs, do you agree that website certificates issued by a qualified trust service provider under an e-IDAS policy would be suitable and allow for the use of all common types of devices (such as computers, tablets and mobile phones) for carrying out different payment services ? Yes.

Question 10: With regards to the frequency with which AIS providers can request information from designated payment accounts when the payment service user is not actively requesting such information, do you agree that the proposed limit of no more than two times a day achieve an appropriate balance between allowing AISP to provide updated information to their users while not negatively impacting the availability of the ASPSP’s communication interface? If not, please indicate what would be in your view the appropriate frequency and rationale for such frequency.

This proposed limit is a deviation from the current practice regarding the MT940/MT942 account statement messages, which can sometimes be requested at 10 minute intervals, albeit at a surcharge. And as such severely limits the ability of AISP's to provide the user with up to date notifications and alerts. Furthermore demanding active user interaction for account updates may result in peak demand at the ASPSP communication interface at random points in time. Why not allow AISP's to query account information at ten minute intervals, thereby limiting the actual user interaction and overhead. The user will only take action when a notification or alert is reported upon reaching a user defined condition.

Please select which category best describes you and/or your organisation [IT services provider "]"

Please select which category best describes the services provided by you/your organisation [Issuing of payment instruments and/or acquiring of payment transactions"]"

Name of organisation JACCOO