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Swedish Bankers' Association (SBA)

Swedish Bankers’ Association (SBA) do not agree with EBA: s choice regarding the transmission of information. This due to several reasons. We regret that EBA is not putting forward solutions that are sufficient for the banks. In order for the register to be workable for our memberbanks, they need information in the register that is updated in realtime. As per the set-up now of the register, the information in it will be AT LEAST one day old. This means that an ASPSP may well engage in a transaction with a TPP even if the TPP has gotten its license withdrawn. This is not acceptable from neither a consumer nor a ASPSP perspective!
This said, SBA appreciates however the NCA: s concerns, described in the consultation paper, as regards the installation and costs associated with updating the national registers in order to meet high demands for a viable technical solution.
The SBA favours adding the “machine readable” functionality as described in point 4.2.21 to ensure a seamless and efficient experience in particular for the purpose of the RTS on Strong Customer authentication (SCA) and Common and Secure Communication (CSC).
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SBA is of the opinion that the consideration by EBA in the consultation paper NOT to include information on credit institutions in the register is very unfortunate. We must have in mind that credit institutions may also want to act as payment initiation service providers (PISPs) as well as account information service providers (AISP). This may result in that the register becomes considerably watered down. Moreover, we take note that EBA in this regard interpret its mandate given in the PSD2 in a very narrow way, in contrast to its views/proposals as regards the RTS on strong customer authentication and secure communication under PSD2.
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Swedish Bankers' Association (SBA) represents banks and credit institutions active in the Swedish banking market. Members are Swedish banks and their subsidiaries and branches of foreign banks.
Lars Rutberg
+46705558418