Response to consultation on the Technical Standards on the EBA Register under PSD2

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Question 1: Do you agree with the option the EBA has chosen regarding the transmission of information by NCAs to the EBA? If not, please provide your reasoning

NA impact for banks
Who is going to report/send in the EBA register a PSP providing services in other member state than their home member state? the host member state or their home member state?

Question 2: Do you agree with the proposed criteria and functionalities related to the search of information in the EBA Register? If not, please provide your reasoning.

The following criteria should be added for searching in the register: Home member state in which TPP is authorized, type of services (PISP, AISP, PIISP), type of payment institution (bank PSP, non-bank PSP)
Bank PSPs (with the different services they may provide: AIS, PIS, PIIS) should be also included in this register in order to have them all in a single and central point.
As for the result of searching, there should be also the information regarding: home member state, host member states where the institution is authorized to provide services, the start date (authorization date) for providing each service and the end date (if case).
Regarding the access to the register, please add the type of users allowed, different levels if case, the maximum no of users per institution, which is the process for getting access to the register.

Question 4: Do you agree with the way how the EBA proposes to fulfil the mandate in terms of the natural and legal persons that will need to be included in the future EBA Register? If not, please provide your reasoning.

Bank PSPs (with the different services they may provide: AIS, PIS, PIIS) should be also included in this register in order to have them all in a single and central point and allow any user searching in the EBA register to see them and find information about these institutions too.

Question 6: Do you agree with the EBA that the contact details, dates of authorisation/registration, and the services provided in the Host Member States, should not be included in the EBA register? If not, please provide your reasoning, which should also include the benefits for payment service users and other interested parties of having this information in the EBA Register.

Dates of authorisation/registration and the services provided in the Host Member States should be included in the EBA register in order to run properly, from business and technical point of view, the new services brought by PSD2 (AIS, PIS, PIIS) and fulfill the objective of open banking.

Please select which category best describes you and/or your organisation

[Other "]"

If you selected "Other", please provide details

Association of banks

Name of organisation

Romanian Association of Banks