Submission #44

Deutsche Bank

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).

It would be preferable to apply the guidelines after the final PSD2 and its implementing rules enter into force. Please consult our response. Many thanks.

Name of organisation Deutsche Bank