Response to consultation on the Technical Standards on the EBA Register under PSD2
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Regardless of the final decision on mentioned above issue, there is a necessity to define the maximal time of execution of particular activity (uploading, updating, validating etc.), especially in manual mode.
Following the recitals 21 and 22, enabling „machine-readable” feature would make EBA register really useful for PSPs and especially ASPSPs to maintain smooth, streamlined processes within PSD2, being a unique, centralized, pan European and trusted source of up-to-date information within highly digitalized world of payments, which will be progressing under PSD2 regime. Moreover, such a feature seems to be in line with the idea and purpose of the register.
This approach may result in some undesired actions, eg. attempts to download data in „screen-scraping” mode, as a consequence of the possibility to download the requested information from the register manually (recital 24), using website forms.
Reliable, up-to-date information on PISP or AISP is the condition of the secure service for the end users. Based on this information, a user could be sure that his/her consent was given to the authorized entity and this authorization was not withdrawn.
Acceptance of this provision in the proposed shape will lead to the necessity of building interfaces to the NCA registers in each Member State for all ASPSPs.
- legal form of the natural or legal person
- contact details (correspondence address, website, e-mail, telephone number)
It could significantly speed up the reaction in case of fraud or other risk issues.
- contact details (correspondence address, website, e-mail, telephone number)
- information on the services provided by the respective institution in the Host Member States
It could significantly speed up the reaction in case of fraud or other risk issues.
Question 1: Do you agree with the option the EBA has chosen regarding the transmission of information by NCAs to the EBA? If not, please provide your reasoning
The proposed approach takes into account an automated transmission of information as well as manual. In our opinion, a manual approach should be limited to exceptional cases and used by authorized representatives of NCA only. Daily processing of the batch file, containing data form NCA, seems to be insufficient because it can cause inconsistency of the data in EBA Register and NCA register. Real-time, online updating is necessary to provide consistency.Regardless of the final decision on mentioned above issue, there is a necessity to define the maximal time of execution of particular activity (uploading, updating, validating etc.), especially in manual mode.
Question 2: Do you agree with the proposed criteria and functionalities related to the search of information in the EBA Register? If not, please provide your reasoning.
We do not agree with EBA attitude regarding the small added value of the „machine-readable” feature of the register.Following the recitals 21 and 22, enabling „machine-readable” feature would make EBA register really useful for PSPs and especially ASPSPs to maintain smooth, streamlined processes within PSD2, being a unique, centralized, pan European and trusted source of up-to-date information within highly digitalized world of payments, which will be progressing under PSD2 regime. Moreover, such a feature seems to be in line with the idea and purpose of the register.
This approach may result in some undesired actions, eg. attempts to download data in „screen-scraping” mode, as a consequence of the possibility to download the requested information from the register manually (recital 24), using website forms.
Reliable, up-to-date information on PISP or AISP is the condition of the secure service for the end users. Based on this information, a user could be sure that his/her consent was given to the authorized entity and this authorization was not withdrawn.
Acceptance of this provision in the proposed shape will lead to the necessity of building interfaces to the NCA registers in each Member State for all ASPSPs.
Question 4: Do you agree with the way how the EBA proposes to fulfil the mandate in terms of the natural and legal persons that will need to be included in the future EBA Register? If not, please provide your reasoning.
We do agree, however it would be useful and practical to register credit institutions as well if they provide AIS and PIS services. It would create and reinforce the role of EBA register as a complete, consistent and unique source of information, also for qualified trust service providers, as it was mentioned in recital 34. Such provision results in the necessity of building interfaces to the different registers in each Member State for all ASPSPs.Question 5: Do you agree with the option the EBA has chosen regarding the detail of information for the natural and legal persons that will be contained in the future EBA Register? If not, please provide your reasoning.
We do agree, however it would be useful to provide also additional data, at least:- legal form of the natural or legal person
- contact details (correspondence address, website, e-mail, telephone number)
It could significantly speed up the reaction in case of fraud or other risk issues.
Question 6: Do you agree with the EBA that the contact details, dates of authorisation/registration, and the services provided in the Host Member States, should not be included in the EBA register? If not, please provide your reasoning, which should also include the benefits for payment service users and other interested parties of having this information in the EBA Register.
We do agree, however it would be useful to provide also additional data, at least:- contact details (correspondence address, website, e-mail, telephone number)
- information on the services provided by the respective institution in the Host Member States
It could significantly speed up the reaction in case of fraud or other risk issues.