Acknowledging that the PSD2 does not explicitly mandate that the EBA provide a ‘machine readable’ register, the EMA believes that the EBA Register presents an opportunity to provide an important element of the trust framework for confirming a PSPs identity and authorisation status by bringing consistency to the data available from National Competent Authority (NCA) registers. This could enable participants in the ecosystem to rely on the information held in the EBA Register to complete part of their due diligence for the purposes of the EBA RTS on SCA and CSC. In order to be an effective resource for this purpose, the EBA Register would have to provide a machine-readable interface.
The EMA further suggests including the ‘trading names’ of the institution in the Register’s search feature, to make it more consumer-friendly. For instance, a PSP may employ different consumer/PSU facing trading or brand names in different Member States. Only enabling a search based on the legal name of the authorised entity assumes that the PSU is familiar with the legal name. Enabling a search by trading/brand name the information in the Register will result in greater consumer utility.
This will of course also require NCA’s to submit trading names to the EBA Register.
It would be helpful if the EBA Register also included relevant payment service and PIS/AIS services offered by Credit Institutions. This would particularly support the consumer protection objectives of PSD2. This is particularly the case when Credit Institutions offer these services on a cross-border basis and where different trading or brand names are used.