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Romanian Banking Association

We need further details /definitions/clarifications with regard to Transactions affected
In the reporting template proposed in Annex 1, at 'Payment services affected' section appear several categories of transactions.
- Please clarify if money remittance transactions affected by an incident which is outside of bank responsibility (the incident being registered on our partner application) should be included in the reporting.
We propose to amend the no of hours for reporting the major incidents from 2 hours to 4 hours from the moment the incident was detected and that's because this time should be correlated with the service downtime of 2 hours included as criteria for classifying an incident as major. There is a need for preparation and analysis of the incident after the 2 hours of downtime, before sending the initial report.
In regard to the instructions provided along with the template, we propose amending the details included at Clients affected. In this category should be taken into consideration only active clients, not passive too, because the last ones are not in fact affected by the incident having in view that they are not doing transactions and are not using the services for long time.
Romanian Banking Association