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Guideline 2: We agree with the proposal.
Guideline 3: The proposal should be amended to allow the comparization of statistical data for the new interface with the average of the KPIs of all the ASPSPs channels.
We agree with the proposal.
We agree with the EBA's conclusion that CAs cannot be required to monitor KPIs as a condition to exempt ASPSPs from a fallback solution. However it should be clarified when and how will the supervisioning authorities conduct this monitorization.
We agree with the proposal.
We agree with the proposal.
We agree with the proposal.
We agree with the proposal.
We agree with the proposal.
Yes we do have several concerns. Do note that it is a very demanding calendar for the vast scope of changes and developments needed regarding processes, systems, solutions and channels that support payment services.
It should be considered an extension of the timeline for an additional 18 months. An ulterior planning phase of the services to be implemented in the new interface would be a good solution to fulfill the directive requirements.
We also consider that the competent authorities should alert all the ASPSPs in advance for all updates in the technical specifications, providing information relating the possible impacts.
We consider that the Guidelines should better detail the requirements of the supporting templates for the presentation of KPIs (guideline 2 and 3)
Yes
susana.conceicao.freitas@cgd.pt
Susana Freitas
+351 218456871
Yes