Optima Consultancy

No - the RTS doesn’t strike the right balance between security and convenience. Merchants should be allowed to have a role in assessing risk and risk based authentication has been successful at removing the friction in customer experience. This is a backward step. Low risk and low value are not the same thing yet it seems that the technical standards are set up with this assumption.
No - the contactless limit needs to address currency volatility and should be increased periodically. It is likely to increase consumer friction and discourage efficient payment methods.
Yes - the approach applies a 'one size fits all' mentality and prevents the use of merchant or PSP knowledge and expertise to determine the level of risk and the required level of authentication to manage that risk. This forces everyone to behave in the same way and may hinder innovative fraud solutions
Assuming a user clicking 'refresh' would constitute a request and allow information to flow then we think twice a day is sufficient for an AISP.
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Scheme fee services, financial modelling, management information and dashboards, regulatory compliance
Mark O'Keefe