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Nordea Bank Finland Plc. Group Legal

Electronic banking services and related technology is subject of rapid technical and operational change. Nordea doesn’t support approach to implement unreleased regulation as a guideline. It is assumed the coming PSD 2 regulation will require fundamental changes in service production. Therefore any premature requirement related to services will cause unnecessary costs and operational risks in the light of the service provision and customer communication.
Nordea does not see any justified ground to set the entry into force 1 August 2015. As a one of the biggest net-bank service providers in Europe we already have schemes to migrate the services to meet Securepay recommendations. However, implementation of these schemes will take relatively long time period. Therefore Nordea favors option B (one step – approach) provided that entry into force will be adjusted in line with the Final provisions and confirmed implementation time of PSD 2 regulation.
Jyri Terämaa
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