Thank you very much for the opportunity to comment the EBA guidelines on internet payments security (EBA/CP/2014/31). We reviewed the guidelines closely and have found that the contents of the EBA guidelines on internet payments security and of the ECB Recommendations for the Security of Internet Payments are quite similar.
As EBA guidelines set the implementation deadline on 1st of August 2015 and ECB Recommendations on 1st of February 2015 the question arises, which implementation date is relevant? Avoiding the unnecessary confusion, please send us an answer. Furthermore, you are kindly asked to explain if »competent authorities« means the National Bank.
Thank you very much for your answer and co-operation.