Question 1: Do you agree with the EBA’s assessments on KPIs and the calculation of uptime and downtime and the ASPSP submission of a plan to publishing statistics, the options that EBA considered and progressed or discarded, and the requirements proposed in Guideline 2 and 3? If not, please provide detail on other KPIs or calculation methods that you consider more suitable and your reasoning for doing so. We agree fully with the answer provided by FDATA Europe to question 1.

Question 2: Do you agree with the EBA’s assessments on stress testing and the options it considered and progressed or discarded, and the requirements proposed in Guideline 4? If not, please provide your reasoning. We agree fully with the answer provided by FDATA Europe to question 2.

Question 3: Do you agree with the EBA’s assessments on monitoring? If not, please provide your reasoning. We agree fully with the answer provided by FDATA Europe to question 3.

Question 4: Do you agree with the EBA’s assessments on obstacles, the options it considered and progressed or discarded, and the requirements proposed in Guideline 5? If not, please provide your reasoning. We agree fully with the answer provided by FDATA Europe to question 4.

Question 5: Do you agree with the EBA’s assessments for design and testing, the options it considered and progressed or discarded, and the requirements proposed Guideline 6? If not, please provide your reasoning. We agree fully with the answer provided by FDATA Europe to question 5.

Question 6: Do you agree with the EBA’s assessment for ‘widely used’, the options it considered and discarded, and the requirements proposed Guideline 7? If not, please provide your reasoning. We agree fully with the answer provided by FDATA Europe to question 6.

Question 7: Do you agree with the EBAs assessment to use the service level targets and statistical data for the assessment of resolving problems without undue delay, the options it discarded, and the requirements proposed Guideline 8? If not, please provide your reasoning. We agree fully with the answer provided by FDATA Europe to question 7.

Question 8: Do you agree with the proposed Guideline 9 and the information submitted to the EBA in the Assessment Form in the Annex? If not, please provide your reasoning. N/A

Question 9: Do you have any particular concerns regarding the envisaged timelines for ASPSPs to meet the requirements set out in these Guidelines prior to the September 2019 deadline, including providing the technical specifications and testing facilities in advance of the March 2019 deadline? We agree fully with the answer provided by FDATA Europe to question 9.

Question 10: Do you agree with the level of detail set out in the draft Guidelines as proposed in this Consultation Paper or would you have expected either more or less detailed requirements on a particular aspect? Please provide your reasoning. N/A