[Openid-specs-fapi] The FAPI Security Model - Under Fire

Tom Jones thomasclinganjones at gmail.com
Fri Mar 2 14:46:56 UTC 2018

That's not what really bothers me. It is the inability of the entities in
this transaction to step up and accept responsibility that sends the wrong

I propose that fapi require EV certs for every consumer facing web site.

thx ..Tom (mobile)

On Mar 2, 2018 4:08 AM, "Joseph Heenan" <joseph at authlete.com> wrote:

Hi Tom,

Under the OpenBanking model, the TPP MUST be registered with the FCA, which
includes a lot of checking, requires liability insurance and documented
processes for dealing with security/data loss/etc, and as I understand it
there are additional checks with the org tries to enrol onto the
OpenBanking directory. Aside from issues like stolen certificates, when a
TPP sends you to a bank to login, the bank will display the TPP name and
there is a good certainty (I'd say more than an EV certificate) that the
organisation name you see in the bank's portal is the one getting access to
your data.

The transitional arrangements are an issue (and only a temporary one), but
importantly transitional participants cannot access the OpenBanking APIs.
They can only operate under screen scraping or other models that were
possible pre-OpenBanking. To use a transitional service, you will be
required to give your banking credentials to the TPP (not to your bank) so
there is a clear difference. I believe many or most of the companies that
could operate under transitional arrangements have applied for
registration/authorisation so they can access OB APIs, though there are one
or two notable exceptions.

The situation with fraud and TPPs operating under the transitional
arrangements are unclear. I have heard of legal opinions that go in both
directions as to whether the bank is liable or not and I doubt it will
become clear unless/until the FCA or a court issue a binding decision, if
significant fraud happens prior to the transitional arrangement ceasing at
the end of next year.



On 2 Mar 2018, at 03:31, Tom Jones <thomasclinganjones at gmail.com> wrote:

here is the quoted detail from the UK FCA https://www.fca.org.uk/

you will note that neither the UK govt (FCA) nor the framework itself take
any responsibility for even assuring that services are who they say they
are, which a EV cert does do.
That means that an approval of the FCA has less assurance than an EV cert.
Now tell me how many bank customers are expected to read these stipulations
on this site?
Who can provide these services?

>From January 2018, companies that are authorised or registered by the
Financial Conduct Authority, or another European regulator, can provide AIS
or PIS.

The FCA and other European Regulators will add AIS and PIS providers to the
registers they keep of all authorised businesses. These registers are
publically available. You can access the FCA’s register
<https://register.fca.org.uk/> to search for a business or contact our consumer
helpline <https://www.fca.org.uk/contact>.

You should be aware that companies that have been providing these services
since before 12 January 2016 do not need to be authorised by the FCA until
the end of 2019, so may not appear on the FCA’s register until a later date.

*Before you use one of these services be alert, and make sure you are
confident that any organisations you share your information with are who
they say they are. You should make sure that you understand the service and
that you are happy with who will be providing it to you.*

Peace ..tom

On Mon, Feb 26, 2018 at 7:50 AM, Tom Jones <thomasclinganjones at gmail.com>

> The gotcha is the determination of what was unauthorized. I recall that
> during the ATM wars a policeman lost his job solely because he had the
> temerity to claim that an ATM withdrawal was unauthorized. He turned out to
> have been correct.
> ..Tom's phone
> On Feb 26, 2018, at 8:33 AM, Joseph Heenan via Openid-specs-fapi <
> openid-specs-fapi at lists.openid.net> wrote:
> Hi Tom,
> Under the UK OpenBanking model, the bank is required to make immediate
> refunds for any unauthorised transactions (and if a TPP was involved and
> negligent, the bank can then try to reclaim that money from the TPP). The
> only exception is if the bank suspects fraud or negligence by the user. I
> believe that setup comes from the EU wide PSD2 requirements (but others
> know that area better than I do).
> How this actually works in practice remains to be seen, as this has only
> been in place for about 6 weeks.
> Joseph
> On 26 Feb 2018, at 15:02, Tom Jones via Openid-specs-fapi <
> openid-specs-fapi at lists.openid.net> wrote:
> the user does not authorize to Zelle. It is just a transport protocol. It
> can either send or request a payment. All the rest is on the user's account
> using the web browser or the bank app. Theoretically the user could
> pre-authorize payment requests, but my banks do not do that. Unlike the ACH
> where pre-auth is common, but not automated.
> The fraud problem is that there are 6 parties to such a transaction
> (consumer, merchant, PISP, bank, UK gov't, attacker). The only party that
> does not understand the system is the consumer, who is the only one that
> bears risk of loss in the UK model. Every other party loses no money no
> matter what happens. This has been tried before in the UK when then ATMs
> were introduced. It did not go well for the consumer. http://www.cl.cam.ac
> .uk/~rja14/banksec.html Trust is an illusion.
> Peace ..tom
> On Sun, Feb 25, 2018 at 11:01 PM, Anders Rundgren <
> anders.rundgren.net at gmail.com> wrote:
>> On 2018-02-25 16:11, Tom Jones wrote:
>>> As near as I can tell Zelle is under user control and ok.
>> I'm sure Zelle is just fine, my "techie" question is if the bank gets
>> anything tangible from the user's authorization to Zelle.
>> The truly evil organization will be the PISP if it is allowed to
>>> operate on the users’ behalf with contracts of adhesion.
>> Well, this appears to be the master plan in the UK.  FAPI/OAuth is
>> essentially morphing into an enrollment system for *persistent* business
>> relations between three parties.
>> This is not common knowledge and may turn out as a source of
>> non-interoperability (at the policy level).
>> Other side effects include something the traditional PSPs didn't have to
>> bother with: Authentication of end users.
>> Fraud will basically be be legalized.
>> The technical capability to perform fraud is more or less a part of most
>> TTPs, be it a CA or a PSP. Trust in services is a combination of
>> regulations, reputation, marketing, and time.
>> The one limiting factor, at least so far as xborder flows go, is
>>> government control of “hot money”. There are good articles just now on the
>>> linkage between kleptocrats and hot money in the Journal of democracy. I
>>> thoroughly recommend them to any thoughtful discussion of this threat. I
>>> suspect that the last thing governments want is friction free money flows.
>>> ..Tom's phone
>>> On Feb 25, 2018, at 12:07 AM, Anders Rundgren via Openid-specs-fapi <
>>>> openid-specs-fapi at lists.openid.net> wrote:
>>>> On 2018-02-25 03:44, n-sakimura via Openid-specs-fapi wrote:
>>>>> Could you guys please elaborate a little more?
>>>> Note: If this list is exclusively intended for discussing pure
>>>> technical issues with the specification rather than the environment where
>>>> it is supposed to used, this message has landed in the wrong forum.
>>>> As far as I understand the decoupled authentication model is indeed
>>>> used by US TTPs like "Venmo" and "Zelle".
>>>> However, all these systems are proprietary and secret so I'm just
>>>> guessing here.
>>>> Going back to the UK and EU, the idea is that independent payment
>>>> providers compete with fees, core features, and user interfaces.  This can
>>>> only be realized if each of them run a network of their own [1] including
>>>> authentication of customers.
>>>> This has major implications beyond security.  In theory this concept
>>>> will foster innovation and competition. In practice it will probably rather
>>>> lead to fragmentation [2] and after an expected shakeout [3], reduce the
>>>> number of national players to one or two which is essentially the opposite
>>>> to the (good) intention.
>>>> The Scandinavian banks separated their Open Banking and Mobile Payment
>>>> efforts with exceptionally good results (adoption rate) for the latter.
>>>> Cheers,
>>>> Anders
>>>> 1] "Pass-through" services like PISPs offer limited power and
>>>> flexibility
>>>> 2] All "Apps" behave differently making consumers and merchants unhappy
>>>> 3] The current consolidation among payment providers shows that volume
>>>> is everything
>>>> Nat Sakimura
>>>>> このメールには、本来の宛先の方のみに限定された機密情報が含まれている場合がございます。お心あたりのない場合は、送信者にご
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>>>>> ------------------------------
>>>>> *From:* Openid-specs-fapi <openid-specs-fapi-bounces at lists.openid.net>
>>>>> on behalf of Tom Jones via Openid-specs-fapi <
>>>>> openid-specs-fapi at lists.openid.net>
>>>>> *Sent:* Sunday, February 25, 2018 4:24:06 AM
>>>>> *To:* Financial API Working Group List
>>>>> *Cc:* Tom Jones
>>>>> *Subject:* Re: [Openid-specs-fapi] The FAPI Security Model - Under Fire
>>>>> yeah, that fits the UK business model.
>>>>> It wont fly in the US however.
>>>>> Peace ..tom
>>>>> On Thu, Feb 22, 2018 at 11:53 PM, Anders Rundgren via
>>>>> Openid-specs-fapi <openid-specs-fapi at lists.openid.net <mailto:
>>>>> openid-specs-fapi at lists.openid.net>> wrote:
>>>>>     Hi FAPIers,
>>>>>     As a curious person I have always wondered how Open
>>>>> Banking/PISP/SCA would combine with Amazon's famous one-click checkout.
>>>>>     Various LinkedIn and Slack conversations have revealed the (ugly?)
>>>>> truth.
>>>>>     The intention (at least in the UK), is giving OAuth tokens
>>>>> "eternal life" and rather letting PISPs (Amazon is expected to be a one),
>>>>> deal with payer authorization.  This faithfully emulates the "card-on-file"
>>>>> system that powers most US based super providers.
>>>>>     Cheers,
>>>>>     Anders
>>>>>     _______________________________________________
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