ETPPA shares its position on FiDA & PSR
At the end of October, ETPPA (European Third Party Provider Association) released two official “Position Papers” on the Financial Data Access (FiDA) on the one hand, and on PSR (Payment Services Regulation) on the other. Both proposals were published by the European Commission on June 28th, and aims at laying down the foundation for the future of financial services.
FiDA: a great potential for a move from Open Banking to Open Finance
If ETPPA welcomes FiDA and foresees it great potential for the development of a strong and wider Open Finance ecosystem, the association still thinks the following key points should be considered, addressed, and integrated in the final legislation:
- A more customer centric approach: “FiDA should focus more clearly on establishing a data access right for consumers and business customers themselves. It should enable customers to take control over their data so that they can access and re-use it as they see fit”.
- Continuous customers access to their data with a user interface: “All financial data holders should be obliged to provide at least one (online or mobile and preferably API-based) customer interface, which is accessible at any time”.
- Highlighting the difference between data re-use and data sharing: “No one wants to share their highly confidential financial data: Open Finance is not about sharing the customers’ data, but about enabling them to unlock and re-use it in a secure way, and at their own will, so that they can profit from a wider choice of service providers whilst maintaining full confidentiality”.
- Interaction between industry players within the framework should be left to self-regulation: “Once data holders are forced to end their monopoly over their siloed customers’ data, they will find interest in a more collaborative approach with other players in the ecosystem allowing them to provide better services themselves”.
- Permission dashboard: “Customers will likely have more different data holders than FISPs, so that it would be easier and less confusing if permission dashboards were provided by the FISP, although ideally, they would be offered independently of both, e.g. as part of an EU digital identity wallet”.
- Definition of FIS and FISP: “these definitions need to be clarified and should be brought in line with the definition of AIS under PSR/PSD3”.
- Safeguarding Europe’s existing Open Finance industry and leadership: “Any new regulation must guarantee the continuation of existing Open Finance services by existing TPPs/FISPs and these should set the minimum standard. However, it should not lead to any regression in any member state”.
PSR: welcoming new provisions that allow the exchange of information
The ETPPA experts focused on both principle and operational improvements needed in the regulation. Here are the operational ones:
- Single payment initiation orders shall not require a contractual relationship with the payer
- Enable PIS to be used for in-store proximity payments
- Immediate contingency access to customer interfaces in case of non-performance (not just non-availability) of the interface used by TPPs
- A TPP must be allowed to provide both AIS & PIS from within one entity
- Permissions dashboard must be based on TPP provided information only
- PIS APIs must accommodate payment journeys with execution upon future instruction by PISP
- Defining SCA to be part of execution (not initiation)
- Possibility to offer the user a specific authentication method
- Differentiating payer, payee, and PISP-initiated payments
- And more
Discover the remaining comments and suggestions in the ETPPA’s PSR position paper
Source: ETPPA