[Openid-specs-fapi] EBA Regulatory Technical Standards

Tom Jones thomasclinganjones at gmail.com
Mon Jun 12 17:57:00 UTC 2017

looks like the US banks have build their own payment network.


On Wed, Jun 7, 2017 at 7:52 AM, Dave Tonge via Openid-specs-fapi <
openid-specs-fapi at lists.openid.net> wrote:

> Hi John and FAPI list members,
> Apologies my mic wasn't working on the call, but here is a quick update on
> the Regulatory Technical Standards on Strong Customer Authentication for
> PSD2.
> The EBA's final draft is here:
> https://www.eba.europa.eu/documents/10180/1761863/Final+
> draft+RTS+on+SCA+and+CSC+under+PSD2+%28EBA-RTS-2017-02%29.pdf
> This draft includes their responses to feedback.
> FAPI sent the following feedback:
> https://www.eba.europa.eu/regulation-and-policy/payment-
> services-and-electronic-money/regulatory-technical-
> standards-on-strong-customer-authentication-and-secure-
> communication-under-psd2?p_p_auth=uy1W7oVC&p_p_id=169&p_p_
> lifecycle=0&p_p_state=maximized&p_p_col_id=column-2&
> p_p_col_pos=1&p_p_col_count=2&_169_struts_action=%2Fdynamic_
> data_list_display%2Fview_record&_169_recordId=1617559
> You will notice in their feedback they ignore the issue of the confusion
> between authentication and authorisation.
> The Commission has recently published a proposed amended version of the
> RTS:
> https://www.eba.europa.eu/documents/10180/1863077/
> RTSEBA24052017.pdf/0e8f0242-8964-473d-8495-184fec286519
> The changes made in the amendment are detailed in this letter:
> https://www.eba.europa.eu/documents/10180/1806975/%
> 28EBA-2017-E-1315%29%20Letter+from+O+Guersent%2C%20FISMA+re+
> Commission+intention+to+amend+the+draft+RTS+on+SCA+and+CSC+-
> Ares%282017%292639906.pdf/efbf06e1-b0e9-4481-88e5-b70daa663cb9
> There is currently uncertainty as to whether the amended draft will be
> adopted. From a bank and TPP perspective here in the UK we believe that the
> amendments will have unintended consequences and will publish a letter
> shortly where we detail our concerns.
> Further to the RTS (which is more about principles than technical
> standards) the Euro Retail Payments Board at the European Central Bank is
> working on actual technical standards to be promoted across the EU for
> PSD2. Their latest report is attached and it is from this report that we
> started consideration of CIBA to support "decoupled" flows.
> FAPI also drafted a letter to the ERPB working group which I've also
> attached.
> I'm happy to answer any questions the group may have regarding these
> documents.
> It is worth noting that in the UK, the Financial Conduct Authority and Her
> Majesty's Treasury have both endorsed the work of OpenBanking Ltd on the
> Open Banking Standard:
> FCA Approach Doc 17.66
> <https://www.fca.org.uk/publication/consultation/cp17-11-draft-approach-document.pdf>
> :
> *During the period before the SCA-RTS becomes applicable, the parties may
> find it helpful to take account of industry standards which are being
> developed as a result of the Competition and Markets Authority’s Open
> Banking Remedy*
> HMT Consultation on PSD2 6.10
> <https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/589023/implementation_of_revised_EU_directive.pdf>
> :
> *The government therefore sees the PSDII implementing regulations as
> providing the legislative foundations on which the Open Banking API
> Standard then sits. Although APIs are only one method by which ASPSPs could
> provide the access to AISPs or PISPs mandated under the PSDII, the
> government believes a commonly utilised API framework will lead to greater
> competition in the retail banking and “third party” services market and
> better outcomes for payers and other end users. *
> On a final note, a number of the "CMA9" banks who are mandated to
> implement the Open Banking Standard have operations in other EU states
> (e.g. Danske, AIB, BOI) and my understanding is that they want to use the
> standard not only in the UK but for all their operations.
> Hopefully we will see increased adoption of FAPI over the coming months.
> --
> Dave Tonge
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