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 [...]
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 [...]
EPIF is glad to share its response to the EBA consultation on the draft Guidelines on the information to be provided for the authorisation as payment institutions and emoney institutions and for the registration as account information service providers.
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 [...]
EPIF is pleased to share its response to the EBA consultation on the Regulatory Technical Standards on strong customer authentication and secure communications under the PSD2. EPIF is supportive of initiatives that introduce more choice to innovation in the European payments sector and believes that we should adapt to customer needs and the rapid pace of [...]
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.
EPIF is pleased to share its position paper on the Commission;s proposal to amend the 4th AMLD. EPIF is supportive of the initiatives that introduces a more robust legal environment and measures to counter terrorist financing and money laundering. EPIF suggests putting together the different existing lists of high risk third countries to avoid contradictions among EU [...]