[Openid-specs-fapi] Update on EBA RTS

Thu Oct 12 08:56:16 UTC 2017

Sorry to bother you with questions. What is described below begs this question: 

Are the banks allowed to support phishing resistant credentials only? 

Any pass-through model will break in this case, as pass-through is an institutionalized phishing. 

I do not think that is the case, as it will put too much technical constraint on the security side and put the users at risk. My read of “and that they are transmitted by the payment initiation service provider through safe and efficient channels;” is that the paragraph is only talking about the security requirements to the PISP that handles the user credentials and is not the requirements to the banks. We need to have it clarified. 

Nat Sakimura 

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From: Openid-specs-fapi [mailto:openid-specs-fapi-bounces at lists.openid.net] On Behalf Of Dave Tonge via Openid-specs-fapi
Sent: Thursday, October 12, 2017 4:52 PM
To: Nat Sakimura <nat at sakimura.org>; Financial API Working Group List <openid-specs-fapi at lists.openid.net>
Subject: Re: [Openid-specs-fapi] Update on EBA RTS

HI Nat

Sorry, slight confusion - this information is not from myself but from one of the members of the ERPB PIS group - but I still think this is positive movement as it provides a way for the industry to move beyond screen scraping.

The conversations are not yet in the public domain, so I don't think I can provide any more details at this point.

Ths issue that concerns me is the line that is being taken about redirect based APIs.

CIBA is good as it allows "decoupled" flows and doesn't count as redirection, BUT even with decoupled flows many are arguing for "pass-through" or "embedded" flows as well - where the banking credentials are entered into a third party site and then "passed through" to the bank via API.

Unfortunately, the text of PSD2 supports their argument:

The payment initiation service provider shall:
(a) not hold at any time the payer’s funds in connection with the provision of the payment initiation service;
(b) ensure that the personalised security credentials of the payment service user are not, with the exception of the user and the issuer of the personalised security credentials, accessible to other parties and that they are transmitted by the payment initiation service provider through safe and efficient channels;

PSD2 Article 66.3   

I think we can make an argument that any method that involves banking credentials being entered on a third party site will severely reduce the "Strong Customer Authentication" methods available for that bank to use.

Dave

On 11 October 2017 at 17:59, Nat Sakimura via Openid-specs-fapi <openid-specs-fapi at lists.openid.net <mailto:openid-specs-fapi at lists.openid.net> > wrote:

Thanks, Dave. 

So, are you saying that ERPB (European) industry group on APIs which you are co-chairing will be vetting the APIs for the compliance? That sounds very positive. 

On the topic of no-redirections, would something like CIBA counts for redirection? IMHO, it does not make sense from the security point of view to have the user put his bearer token aka password into the TPP apps. With CIBA, redirection is not involved but we can still avoid the above problem. 

Best, 

---
Nat Sakimura
Research Fellow, Nomura Research Institute
Chairman of the Board, OpenID Foundation

On 2017-10-11 23:21, Dave Tonge via Openid-specs-fapi wrote:

Dear FAPI Working Group

As discussed on the call, here is the latest information we have on the RTS:

1.       RTS is in the final stages of approval by EC – expected early Nov (effective date likely to be Sept 2019). On screen scraping (known as the fall back option) the draft EC proposal is that PSP firms will be able to seek a regulatory exemption, to be granted by the competent authority, to avoid having to supporting screen scraping at all. To obtain an exception will require a vetting process based upon at least the following criteria:

a.       The APIs are technically PSD2/RTS compliant

b.      They are available 3 months ahead of implementation

c.       They have been market tested

d.      They adhere to specific performance criteria

The EC also proposes that the ERPB (European) industry group on APIs, that I established and which I co-chair, could, de facto, become the industry group to ‘vet’ APIs with support and active participation by EC (DG FISMA and DG COMP) and including the national competent authorities (like FCA). This is a very significant and incredibly positive development as the EC is effectively saying that they want to ‘bless’ industry to guide them, the regulators,to get this right.

Therefore, the OB PSD2 APIs would conceivably have to go through this vetting and approval process, which illustrates the importance of aligning our PSD2 roadmap assumptions based on the direction set at European level. This will help to avoid divergence between standards at the national level.    

2.       There have been some questions recently about the redirection model for PSU authorisation and whether it is PSD2 compliant. Directionally, the EC supports the view that “APIs must support all authentication procedures provided by the ASPSP to the PSU, but must not require the TPP to have to use the redirect option”. Strictly speaking, the EC is not banning redirection, but it does support the view that a TPP should not have to be forced to use it. Logically therefore, it cannot be the only option available. The EC also supports the view that the TPP must be “free from constraints to innovate the design of the user interface for the PSU’s consent and authorisation journey for both PIS and AIS”. Within the ERPB API group we agreed yesterday in Brussels to go into detail on this topic to define what is acceptable based on the three methods of redirect, pass-through and embedded. The objective is to set a ‘bar’ of acceptability to be blessed by the EC as a one of the criteria by which to ‘vet’ API standards for conformity with PSD2/RTS.

-- 

Dave Tonge

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10 Temple Back, Bristol, BS1 6FL

t: +44 (0)117 280 5120

Moneyhub Enterprise is a trading style of Momentum Financial Technology Limited which is authorised and regulated by the Financial Conduct Authority ("FCA"). Momentum Financial Technology is entered on the Financial Services Register (FRN 561538) at fca.org.uk/register <http://fca.org.uk/register> . Momentum Financial Technology is registered in England & Wales, company registration number 06909772 © . Momentum Financial Technology Limited 2016. DISCLAIMER: This email (including any attachments) is subject to copyright, and the information in it is confidential. Use of this email or of any information in it other than by the addressee is unauthorised and unlawful. Whilst reasonable efforts are made to ensure that any attachments are virus-free, it is the recipient's sole responsibility to scan all attachments for viruses. All calls and emails to and from this company may be monitored and recorded for legitimate purposes relating to this company's business. Any opinions expressed in this email (or in any attachments) are those of the author and do not necessarily represent the opinions of Momentum Financial Technology Limited or of any other group company.

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