van den Berg AG

Yes we agree. In Germany there are two communication standards for the handling of bulk-transactions called EBICS and FileAct. We assume that the RTS also apllies to EBICS and to FileAct.
Yes, we agree.
No, we are not aware of other threats.
White list.
The white list can lead to disadvantages for small merchants as compared to big merchants like amazon. In the three corner model (e.g. Paypal) it is possibke to put all the merchants who are connected to the PSP on the white list. In such a case we have no level playing field as compared to the banks connected in a four corner model. A problem could also be a white list which is presented by the payers bank and which can be accepted by the payer. This can disadvantage to those merchants who are not on a that list. It would be helpful if such a list would also include bouderies for each paypee.
Instant Payments is a new payment instrument which will be launched in November 2017. Instant Payments will be available 24/7 and the amount is made available to the payee within a few seconds. The project is forced by the ERPB and the ECB. In contrast to payment instruments used today at the POS and in e-commerce, Instant Payments is a push procedure. When using Instant Payments the bank of the payee does not know if the payment was inittiated at the POS or via e-commerce - but there are different bounderies for the POS (50 EUR) and e-commerce (10 EUR). This does not make sense at all.
Yes, we agree but we see an advantage in clarifying definitions to relevant terms.
The technical specification of the communication interface is made available for free and publicly on the website. It is important that the documentation is available in english. Instant Payments is a new payment instrument which will be launched in November 2017. Instant Payments will be available 24/7 and the amount is made available to the payee within a few seconds. The project is forced by the ERPB and the ECB. In contrast to payment instruments used today at the POS and in e-commerce, Instant Payments is a push procedure. When using Instant Payment at the POS there is no acceptance device needed. The information that the amount is available is given by the payees bank to the payee.
The industry standard ISO 20022 should be used
A qualified certificate for website authentication is sufficient
The frequency of two times a day is sufficient. Starting the App of the AISP should be interpretated as PSU request.
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Yes
armin.harst@vdb.de
Armin Harst
0049-2406-954312
Yes