ASF

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The ASF welcomes the opportunity to respond to Consultation Paper dated on 12 August on
the draft Regulatory Technical Standards specifying the requirements on strong customer authentification and common and secure communication under PSD2.

As a unique representative body of all the French specialised credit institutions and financial institutions which represents 285 entities, ASF contributes to an appropriate recognition of the specialised financial activities like equipment and real estate leasing, factoring, consumer credit and auto loans and leases, mutual guarantee societies which – with an outstanding of more than €220 billion in 2015 – accounts for about 20% of total amount of credits to the real economy in France.

We do consider that it is fundamental to draw your attention to the point related the three-party card schemes.

The article 98 of the Directive introduces the exemptions from the application of article 97 “Authentication”. The exemptions shalll be based on the following criteria :

(a) the level of risk involved in the service provided ;
(b) the amount, the recurrence of the transaction, or both ;
(c) the payment channel used for the execution of the transaction.

In accordance with the article 98, we suggest that the future RTS Guidelines do not oblige three party card schemes to be “compliant” with a strong customer authentification for the following reasons.

Firstly, many three-party card schemes are not general purpose card payment schemes.

Secondly, the three-party card schemes operate on a national basis with a small market share of the cards market and with a small limited number of merchants.

Futhermore, the level of security measures taken depends on the recurrence and the amount of the transaction.

Finally, these three-party cards are subject to a low number of fraud : in 2015 the percentage of fraud raises at 0.068 % . We explain this low rate by a limited use of these three-party cards in a closed loop system. The compliance with the strong customer authentification is disproportionate to the level of risk and the volume of transactions.

Therefore, we suggest to modify the article 8 of the draft RTS specifying the requirements on strong customer authentification and common and secure communication under PSD2 to take into account these features.
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As a unique representative body of all the French specialised credit institutions and financial institutions which represents 285 entities, ASF contributes to an appropriate recognition of the specialised financial activities like equipment and real estate leasing, factoring, consumer credit and auto loans and leases, mutual guarantee societies which – with an outstanding of more than €220 billion in 2015 – accounts for about 20% of total amount of credits to the real economy in France.
[Issuing of payment instruments and/or acquiring of payment transactions"]"
Corinne Denaeyer