Submission #46

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OP Pohjola Group Central Cooperative

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).

OP Group prefers a two step approach, i.e. to have the EBA guidelines to enter into force on 1 August 2015, and the stronger requirements based on PSD2 to be enter into force at a later stage (following the forthcoming PSD2 implementation guidelines).

Although in principle a one step-approach in which all security requirements would be implemented at the same time would be preferable, the proposed timetable - august 2015 - is completely unrealistic from the technical implementation point of view. As the exact nature and formulations of PSD2 are still not yet known, it would not be possible to achieve compliance within the very short time frame available from the point the PSD2 requirements and related technical specifications are finally specified and agreed. Major ICT changes - which very likely are necessary to comply with PSD2 requirements - take at least 12-18 months to execute. Thus the ideal solution preferred by OP Financial Group would be to have a single step approach, combining both the EBA guidelines and PSD2 requirements with the entry in force following the PSD2 implementation timetable.

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Name of organisation OP Pohjola Group Central Cooperative