We would like to thank the European Commission for the opportunity of commenting on the Public consultation on the operations of the European Supervisory Authorities. EPIF would hope that the ESA review will provide the opportunity to implement the following three suggestions: The EBA Regulation should enshrine binding wording giving the EBA a clear mandate to [...]
EPIF has highly appreciated the constructive dialogue with the European Commission and the EBA during this process but nonetheless has some final remakrs on the revised draft. EPIF is of the view that card-based transactiobs should be exempt from the dynamic linking requirement. EPIF suggesting relacinx the requirements to keep the maximum transaction amount to EUR 50 [...]
EPIF is pleased to share its response with the ESAs emphasising the need to ensure that the legislation in practice works also when non-bank PSPs are involved in the payment chain. EPIF is of the view that the following two principles must be made clear: 1) The bank where the Payer initiates a payment transaction needs [...]
EPIF welcomes the European Commission’s work to update the framework sanctioning criminal activity where non-cash means of payment fraud are concerned. By improving the effectiveness of prosecution of criminal activity where prevention has failed is, this initiative will foster trust and security in the online environment and contribute to the EU’s Digital Single Market.
EPIF is pleased to share its response to the Commission consultation on restrictions on payments in cash. EPIF believes that EU-wide action to restrict payments in cash is unnecessary at this time. Cash remains the payment method of choice for many people, due to its convenience, its portability and its universal acceptance.
EPIF is pleased to share its response to the Article 29 Working Party Guidelines on Data Protection Impact Assessment (DPIA). For EPIF, the central question is what ‘high risk’ means to the regulators and to companies. Companies need legal certainty of how the rules will be applied.
EPIF generally agrees with the proposed Guidelines 1-6 but underlines the importance of the Home State Principle and its application to the complaints procedure for alleged infringements of the PSD2.
EPIF is glad to share its response to the consultation on Central Contact Points. EPID agree with the princple of CCP but is of the view that it is crucial that the EBA provides guidance to Member States on the form of CCPs to avoid Member States to take on different approaches.
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 [...]
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 [...]