Submission #23

French Banking Federation

Do you prefer for the EBA guidelines a. to enter into force, as consulted, on 1 August 2015 with the substance set out in this consultation paper, which means they would apply during a transitional period until stronger requirements enter into force at a later date under PSD 2 (i.e. a two-step approach); or to anticipate these stronger PSD 2 requirements and include them in the final guidelines under PSD 1 that enter into force on 1 August 2015, the substance of which would then continue to apply under PSD 2 (i.e. a one-step approach).

The FBF favors a two-step approach (option a) and thinks that the EBA guidelines better enter into force on 1 August 2015 as set out in this consultation paper, and then, once EBA issues its draft technical standards resulting from the entry into force of the DSP2, and once the Commission has validated and published them, stronger security requirements shall enter into force.

Upload files Final FBF Answer to EBA CP Security of Internet Payments vf.docx

Name of organisation French Banking Federation