Brussels, September 16, 2020: ETPPA response to the EDPB guidelines on the interplay of PSD2 and GDPR consultation
ETPPA would welcome the redrafting of the guidelines based on the input of a more balanced representation of all relevant stakeholders including TPPs. Many are based on wrong assumptions and therefore incorrect or not applicable. It is very surprising that the focus of these guidelines is on TPPs, rather than all PSPs acting under PSD2. Applying the proposed guidelines to ASPSPs and their processing of personal data would make banking and payments impossible.
Click here to view our response.
Brussels, August 27, 2020: ETPPA feedback to EPC consultation on SEPA Request-to-Pay (SRTP)
The EPC’s so-called SEPA Request-to-Pay rulebook deviates from the ERPB recommendation by proposing solely a 4-corner model suitable only for a bank-centric and interchange-enabling scheme. We strongly recommend to rather follow an Open RTP approach, which uses and expands the Open Banking/PSD2 framework, rather than developing a separate independent scheme, which starts from scratch, duplicates all efforts and is likely to create unlevel playing fields between banks and bank-independent PSPs and SPs in the payments ecosystem.
Click here to view our feedback.
Brussels, August 26, 2020: ETPPA feedback to EC consultation on the AML Action Plan
ETPPA responded to the EU Commission consultation on the AML Action Plan. ETPPA favours and would welcome a harmonisation of AML rules at an EU level in targeted areas, combined with the effective application of a risk based approach. It questions, however, the need to include Third Party Providers into the scope of the AML rules due to recognised low risk in particular in relation Account Information Service Providers (AISPs), as they do not conduct financial activities.
Click here to view our feedback.
Brussels, July 25, 2020: Press Release SEPA API Access Scheme
The European Third Party Payment Providers Association (ETPPA) would like to welcome the decisions of the European Retail Payments Board (ERPB) earlier this month to confirm ETPPA as a full member representing the Third Party Provider industry and to reinstate the work on a SEPA API Access Scheme later on this year, as described in their statement. ETPPA’s preference would have been to restart it right away, but we can appreciate the ERPB’s desire for some preparatory steps beforehand.
Click here to view the press release.
Brussels, July 24, 2020: ETPPA provides feedback to EPC consultation on payer-presented data
ETPPA today provided feedback to the EPC's consultation about the “Technical Interoperability for MSCTs based on payer-presented data”. We have suggested that the MSCT ecosystem is much more complex than described and that considering all the interactions between the various players will therefore need a more complex model, which we have provided directly to the working group and which we hope will be considered, because that will be essential for creating a truly level playing field between all types of Mobile SCT Service Providers including PISPs.
Click here to view our feedback.
Brussels, July 6, 2020: ETPPA provides feedback to EBA consultation on AML/CTF
ETPPA today provided feedback to the EBA's consultation on the guidelines for AML / CTF risk factors. We have raised some fundamental concerns on the scope of the implied AML requirements for AISPs and PISPs, and in particular for AISPs that do not conduct financial activities. We requested that the AML guidelines are not finalised until the conclusion of the EU Commission’s consultation. If there are any AML requirements for PISPs, it should be clarified that their “customers” are in almost all cases the online-merchants, not the account holders.
Click here to view our feedback.
Brussels, June 26, 2020: ETPPA provides feedback to EC consultation on Retail Payments
ETPPA today also provided feedback to the EC's consultation on a retail payments strategy for the EU. We are advocating an open PSD2-based approach to challenge the dominant cards and wallets from the East and West with superior instant payments technology to regain EU payments sovereignty. The ETPPA's European Retail Payments Framework (ERPF), which is designed to be accessible to all EU citizens in all member states within very short timescales by facilitating interoperability and competition between multiple retail payment solutions, still needs support and some effort from the authorities. So we also used this opportunity to explain and request the missing bricks.
Click here to view our feedback.
Brussels, June 26, 2020: ETPPA provides feedback to EC consultation on Digital Finance
ETPPA has provided feedback to the EC's consultation on a new digital finance strategy for Europe / FinTech action plan. In line with the feedback we provided earlier this year to the UK FCA, we are suggesting a GDPR-based approach for the access and portability of other financial and non-financial data, rather than extending PSD2-type licenses and regulations beyond payments data.
Click here to view our feedback.
Brussels, June 9, 2020: ETPPA provides feedback to EPC SCT Inst consultation
ETPPA has provided feedback to the European Payments Council's SEPA Instant Credit Transfer Rulebook - 2020 Change Request Public Consultation Document. We are supporting the change requests suggested by EuroCommerce to add features to SCT Inst enabling better competition with card schemes, and thereby opposing the EPC recommendation to downstream these features to their new (proprietary) Request-to-Pay (RTP) scheme, because these would then not be available to PSD2-based open RTP schemes.
Click here to view our feedback.
Brussels, June 8, 2020: ETPPA welcomes EBA’s recognition of obstacles
The European Third Party Payment Providers Association (ETPPA) would like to welcome the European Banking Authority’s new “Opinion on obstacles to the provision of third party provider services under the Payment Services Directive” dated June 4, 2020.
This long awaited Opinion positively confirms a number of key areas that the ETPPA has been advocating for on behalf of its members, which are in the clear interest of consumers and merchants across Europe who use these services every day.
Click here to view the full statement.
Brussels, June 5, 2020: ETPPA is excited to welcome Plaid as new full member! #plaid
Plaid is a US-headquartered payments company that operates across seven countries globally. In Europe Plaid is licensed as an AISP and covers Spain, France, Ireland, the Netherlands and the UK. It is great to have Plaid on board to strengthen the voice of payment innovators in Europe and we look forward to supporting Plaid across the European payments regulatory and industry space!
Brussels, March 17, 2020: ETPPA provides feedback to UK FCA Open Finance consultation
ETPPA has provided feedback to the UK Financial Conduct Authority's Call for Input to explore the opportunities and risks arising from open finance. Rather than extending PSD2-type licenses and regulations beyond payments data, we are suggesting a GDPR-based approach for the access and portability of other financial and non-financial data.
Click here to view our feedback.
Brussels, January 30, 2020: Industry veteran Dr. Ruth Wandhöfer joins ETPPA
ETPPA are pleased to announce industry veteran Dr. Ruth Wandhöfer joining as strategic adviser. Ruth brings with her more than 18 years of regulatory and banking experience. Her focus will be on promoting the interests of European TPPs, and contribute to the constructive dialogues with banks, central banks, market infrastructures, regulatory and industry bodies. Ruth commented “I am pleased to support the ETPPA and its members in looking at the intended and unintended consequences of established, recent and yet to be written rules and regulations, helping European TPPs to continue to provide safe, scaleable and user friendly solutions to the benefit of European consumers and merchants.
I will be reaching out to all members in the coming weeks to help prioritise our efforts and look to deliver what our members need from the ecosystem.”
Click here to view the announcement.
Brussels, November 20, 2019: ETPPA letter to EC VP Valdis Dombrovskis and the ECB's ERPB Chair about the creation of a European Retail Payments Framework
Click here to view the letter.
Brussels, September 6, 2019: Joint PSD2 Task Force Update: Banks and TPPs provide a progress update of their joint PSD2 task force to the European Commission, highlighting the urgency for National Competent Authorities to allow flexibility prior to the 14-Sep deadline
Click here to view the letter.
Brussels, June 18, 2019: Press Release: Next Stage of EU Directive “will create widespread customer disruption affecting many millions of consumers and businesses throughout Europe” says Fintech bodies
Click here to see the press release.
Click here to download the The Unintended Consequences of PSD2 RTS document.
Strasbourg, April 16, 2019: Letter from MEP Markus Ferber to European Commission Vice-President Valdis Dombrovskis on the "Implementation of PSD2"
Markus Ferber, member of the European Parliament and their PSD2 trilogue lead, emphasizes the most fundamental requirements for a smooth PSD2 implementation to ensure that there will not be any deterioration of existing TPP services post 14-Sep-2019.
Click here to view the letter.
Brussels, April 9, 2019: Letter to all EU National Competent Authorities in charge of banking supervision on "PSD2 TPP Business Continuity"
ETPPA asks all NCAs to support TPP business continuity post 14-Sep-2019 by ensuring that banks and other ASPSPs cannot block any of their user interfaces for contingency measures and allowing TPPs to fulfil their eIDAS identification obligations unilaterally via HTTP header signatures.
Click here to view the letter.
Brussels, April 4, 2019: European Third-Party Provider Association established
The non-profit organisation has been established by the founding members Bankin’, Eurobits, PPRO, Sofort, Trustly
Click here to view the news item.