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AFUB (Association française des usagers des banques)

The AFUB-FBUA (French Bank Users Association) expresses its approval of the objectives and means deployed in order to achieve transparency and confidence in the relevant sectors on behalf of the consumers.
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The AFUB-FBUA (French Bank Users' association) agrees with the Guidelines on information required from applicants for registration of the provision of the service of account information services as set out in 4.2. However, our organisation believes that the guidelines should be modified as follows:

1) The modalities of the periodical statistical appreciation permitting to determine the number (or percentage) of incidents in comparison with the total number of operations; that is including those with and without incidents should be included;

2) Additionally, the modalities and delay of response in relation with complaints of customers should be specified.
Our organization advocates this position, as requesting precisions regarding the monitoring and management of the risk of fraud will not permit the competent authority to control the concerned establishment’s compliance with the relevant requirements.

Effectively, since the directive DSP 2 2015/2366/UE, in the case of a fraud, the establishment must reimburse IMMEDIATELY the victim. This assumes that the control is exercised on this issue.
An engagement relating to the timing of the management of complaints would thus ensure compliance on behalf of the Account information Service providers regarding consumers.
Therefore, the establishment must commit to specify the delay by which it engages itself to fulfill its obligations towards the consumers.
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Caroline Fitzsimons
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