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Response to consultation on Guidelines aimed at standardisation of fee terminology for payment accounts in the EU
Go backQuestion 2: Are there any additional requirements that you would suggest adding?
No, PAD provides an exhaustive list of criteria that may be applied by the CAs and no other criteria should be taken into account.Question 3: Do you agree with the analysis of the cost and benefit impact of the guidelines?
Sources of the supportive data should not only be „statistically robust”, but reliable as well. On the other hand, ad hoc collection of data or collection from firms should certainly not be obligatory, as it may generate excessive costs for both CAs and PSPs. As a compromise, the methodology used by CAs should be made publicly available by them.Name of organisation
Prudentiz (Poland)
