EPIF response to Questionnaire on the EBA Register

EPIFsupports the PSD2’s creation of a central EBA Register, which will serve as a one-stop-shop for consumers and businesses alike to access up-to-date information about the Payment Service Providers (PSPs) they interact with. From a Payment Institution’s (PI) perspective, EPIF is of the view that the Register should provide capabilities for real-time partner verifications through fast [...]

2018-01-12T11:06:56+00:00

EPIF response to EBA Questionnaire related to the RTS on CCPs

EPIF would welcome confirmation as to whether agents who are not acting on behalf of a PI in providing payment services. The CCP should be able to manage country level reporting to the regulator but it is not necessary for the CCP to conduct its own additional offsite or onsite audits or investigations. EPIF would welcome [...]

2018-01-12T11:07:14+00:00

Co-signed letter to Commissioner Dombrovskis on RTS on SCA

EPIF is pleased to have co-signed a letter together with 18 other associations on the draft RTS on SCA. The letter provides the high-level postion of major payments industry operators with regards to the draft RTS on SCA. The letter ackknowledges the need for a Transaction Risk Analysis (TRS), supports a result-oriented approach and encourages [...]

2018-01-12T11:07:34+00:00

EPIF response to the EBA GL on major incident reporting

EPIF is pleased to share its response to the EBA Guidelines on major incident reporting under the PSD2. These draft Guidelines set out the criteria, thresholds and methodology to be used by payment service providers in order to determine whether an operational or security incident should be considered as major and, therefore, be notified to the [...]

2018-01-12T11:07:55+00:00

EPIF Position Paper On The EBA Gl ON PI Insurance

EPIF does not agree on the requirement of undertakings and believe that the minimum monetary amount  should always cover the potential liabilities. EPIF does not agree on the indicators under the type of activity criteria should be calculated and believes that the size of activity indicator is exaggerated.

2018-01-12T11:09:06+00:00

EPIF Position Paper on the EBA Guidelines on PI Insurance for PSPS’

EPIF is pleased to share its position paper on the EBA Guidelines on PI Insurance  for PSPS’. There appears an over-reliance on insurance to underpin the new TPP market. This appears to be the assumed solution even in the title of the ‘Guidelines on Professional Indemnity (PI) insurance for PSPs’. This is unfortunate since there is no such [...]

2018-01-12T11:09:43+00:00

EPIF Response to EBA consultation on Regulatory Technical Standards on passporting under PSD2

The European Payment Institutions Federation is pleased to share its responses to the EBA consultation on Regulatory Technical Standards on passporting under the PSD2. EPIF suggests that Host State competent authorities should provide reference to applicable main regulations and reporting requirements for Payment Insitutions using their passporting rights in the Host Country. EPIF strongly suggest no [...]

2018-01-12T11:10:04+00:00
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