Submission #154

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The Association of Foreign Exchange and Payment Companies

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?

We agree with the reasoning.

Article 8(1)(b) states that the exemption applies where the payer initiates a contactless electronic payment transaction at a point of sale and the cumulative amount of previous non-remote electronic payment transactions initiated via the payment instrument offering a contactless functionality without application of strong customer authentication does not exceed €150. We think that this €150 limit should be for a set period of time, for example one day or one week. If there is no limit of time then the exemption will become meaningless quickly for a lot of payers.

Article 8(2)(d)(ii) states that the exemption applies where the payer initiates a remote electronic payment transaction where ...the individual amount does not exceed €10 and the cumulative amount of previous electronic payments transactions initialed by the payer without the application of strong customer authentication does not exceed €100. We think that the €100 limit should be reset after a certain period of time. If the €100 limit was cumulative and applied forever the exemption would become meaningless quickly for a lot of payers.

It would be useful to have a definition of electronic payment transaction. Does this definition include the PSP making the payment transaction when the instruction comes through an email or telephone. If so, what constitutes a non-electronic payment transaction.

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? Same as question 4.

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? No comment.

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 ? No comment.

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. No comment.

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Each of our member conducts foreign exchange and money remittance on behalf of their customers.

Name of organisation The Association of Foreign Exchange and Payment Companies