The Bank Association of Slovenia, Subiceva ulica 2, SI – 1000 Ljubljana, Slovenia

Yes.
Yes.
Yes.
Yes.
Bank 1: We propose that article 8 point 1 ii is excluded from TS: is not good users’ experience.
Article 8 point 1 b i and ii
Article 8 point 2 d i and ii
Rules should be defined by national regulatory body: 50 € have different values in different countries (UK versus Slovenia)

Bank 2: We propose that each PSP has discretionary right to enforce SCA for all transactions regardless that some transactions meet the exemption criteria, especially provision in article 8, paragraph 2d (page 34).
Yes.
Article 22, point 5: AIS provider shall receive information only when user is requesting such information.
Yes - end to end.
Certificates are acceptable for communication between PSPs, but not between PSPs and client (such as computers, tablets and mobile phones).
AIS providers shall receive information only when user is requesting such information.
[Other "]"
The Bank Association of Slovenia, Subiceva ulica 2, SI – 1000 Ljubljana, Slovenia
[Other"]"
Primary objectives of the Association are:
- advocates the common interests of its members in relation to the state and financial authorities
- performs numerous tasks for the benefit of its members which are important for their banking operations
- suggests the uniformity, modernisation, organisation, working technology and standardisation of all financial operations conducted by its members
- provides financial and legal consulting
- engages experts on behalf of its members
- formulates projects in the area of research and development of financial operations and banking
- organises professional training of banking personnel
- organises information and publishing activities
Aleksandra Zibrat