[Openid-specs-fapi] EBA Regulatory Technical Standards

Nat Sakimura n-sakimura at nri.co.jp
Tue Jun 13 03:58:01 UTC 2017

I will add this to tomorrow’s agenda. 


>From the article, what I gathered is that it is a phone number/email address to account identification info discovery service. 

Is that correct? 


In Japan, a bank account to another bank account transfer is almost instantaneous and the fee is free in many cases. 

The user interface sucks a bit as you have to identify the recipient account by specifying bank name/number, branch name/number, account type, and the account number. (In most cases, you can bookmark it so that you do not have to specify them from the second time.) If there is a phone number to account info service, it will be pretty much the same, I guess. 


One of the problem that I find with the phone number / email approach is the possibility of the identifier recycle but I guess it is coped by showing the use the recipient name etc. It would work unless the new owner has the same name as the old owner of the number/email. Email is more likely to fall into this pitfall as  <mailto:John.Smith at yahoo.com> John.Smith at yahoo.com probably would be picked up by another John Smith. 



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From: Openid-specs-fapi [mailto:openid-specs-fapi-bounces at lists.openid.net] On Behalf Of Brian Costello via Openid-specs-fapi
Sent: Tuesday, June 13, 2017 4:17 AM
To: Tom Jones <thomasclinganjones at gmail.com>; Financial API Working Group List <openid-specs-fapi at lists.openid.net>; Dave Tonge <dave.tonge at momentumft.co.uk>
Subject: Re: [Openid-specs-fapi] EBA Regulatory Technical Standards


Indeed.  This is the “upgrade” from ClearXchange, with Early Warning (bank owned) as the service provider.


From: Openid-specs-fapi [mailto:openid-specs-fapi-bounces at lists.openid.net] On Behalf Of Tom Jones via Openid-specs-fapi
Sent: Monday, June 12, 2017 10:57 AM
To: Dave Tonge <dave.tonge at momentumft.co.uk>; Financial API Working Group List <openid-specs-fapi at lists.openid.net>
Subject: Re: [Openid-specs-fapi] EBA Regulatory Technical Standards


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


https://www.nytimes.com/2017/06/12/business/dealbook/mobile-banking-zelle-venmo-apple-pay.html?module=WatchingPortal <https://www.nytimes.com/2017/06/12/business/dealbook/mobile-banking-zelle-venmo-apple-pay.html?module=WatchingPortal&region=c-column-middle-span-region&pgType=Homepage&action=click&mediaId=thumb_square&state=standard&contentPlacement=4&version=internal&contentCollection=www.nytimes.com&contentId=https%3A%2F%2Fwww.nytimes.com%2F2017%2F06%2F12%2Fbusiness%2Fdealbook%2Fmobile-banking-zelle-venmo-apple-pay.html&eventName=Watching-article-click&_r=0> &region=c-column-middle-span-region&pgType=Homepage&action=click&mediaId=thumb_square&state=standard&contentPlacement=4&version=internal&contentCollection=www.nytimes.com&contentId=https%3A%2F%2Fwww.nytimes.com%2F2017%2F06%2F12%2Fbusiness%2Fdealbook%2Fmobile-banking-zelle-venmo-apple-pay.html&eventName=Watching-article-click&_r=0



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



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 <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> &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:



The changes made in the amendment are detailed in this letter:



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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