Month: November 2016

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FDATA responds to EBA insurance consultation

The Financial Data and Technology Association has submitted a response to the EBA consultation “Guidelines on the criteria on how to stipulate the minimum montary amount of the professional indemnity insurance under PSD2”.

There were seven questions, which can be seen below along with FDATA’s answers:

Question 1: Do you agree with the requirement that competent authorities require undertakings to review, and if necessary re-calculate, the minimum monetary amount of the PII or comparable guarantee, and that they do so at least on an annual basis, as proposed in Guideline 8?

FDATA agrees with the principle behind this proposal. It is good for all market participants that operators are adequately insured, and we support the concept of competent authorities being in control of that regime.

However we would stress the need to minimise the administrative burden on the operators, especially in the case of start-ups who have little resource for such tasks. If the administrative burden is significant it could be seen as a barrier to entry to the market.

Question 2: Do you agree with the formula to be used by competent authorities when calculating the minimum monetary amount of the PII or comparable guarantee as proposed in Guideline 3? Please explain your reasoning

We have applied the proposed formula to some theoretical companies of different sizes, and we believe that the financial outcome tends to be fair. However whilst the outcome seems reasonable, we have concerns that the formula itself is overly complicated.

We would therefore encourage more work to investigate whether the same equitable outcome could be achieved through a less complicated formula.

Question 3: Do you agree with the indicators under the risk profile criterion and how these should be calculated, as proposed in Guideline 5? Please explain your reasoning.

As we noted in answer to question two, we generally support the indicators and the result they produce. However we are concerned that some companies, start-ups in particular, will find the system onerous and complicated. The EBA needs to be satisfied that a similar outcome cannot be achieved through a less complicated formula.

Question 4: Do you agree how the indicators under the type of activity criterion should be calculated, as proposed in Guideline 6? Please explain your reasoning.

See answer to question 3.

Question 5: Do you agree how the indicators under the size of activity criterion should be calculated, as proposed in Guideline 7? ? Please explain your reasoning

See answer to question 3.

Question 6: Do you think the EBA should consider any other criteria and/or indicators to ensure that the minimum amount is adequate to cover the potential liabilities of PISPs/AISPs in accordance with the Directive? Please explain your reasoning.

We do not believe the EBA need consider any other criteria or indicators to set a minimum amount, however we would encourage the EBA to consider criteria which would enable the setting of a maximum amount of adequate cover.

Question 7: Do you have any other comments or suggestions that you think the EBA should consider in order to ensure that the minimum amount is adequate to cover the potential liabilities of PISPs/AISPs in accordance with the Directive? Please explain your reasoning.

We believe that it is important that the EBA consults with the insurance industry to ensure that the calculations correspond with the current insurance industry assessment of risk for AISPs and PISPs.

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FDATA ANNOUNCES ADDITION OF CALLCREDIT AS IMPLEMENTATION ENTITY GETS UNDERWAY

The Financial Data and Technology Association (FDATA) has announced another new member, with the addition of the UK’s second largest credit reference agency and consumer data manager Callcredit Information Group.

FDATA’s members provide innovative financial applications and services to empower customers to make better decisions and take fuller control of their financial lives across all their accounts, credit cards, loans and investments.

Commenting, FDATA’s Executive Director Andy Maciver said:

“The addition of Callcredit to FDATA’s membership is a hugely significant moment for our Association. In addition to members from other areas of the fintech industry such as personal finance management and challenger banking, we now have the majority of the credit reference industry in the membership.

“As we commence the working of the Implementation Entity, we enter a critical phase for open banking. Callcredit’s considerable expertise will be invaluable in helping FDATA navigate its way through the process.”

Commenting, Mark Davison, Chief Data Officer at Callcredit, said:

“The industrial marketplace we see is facing change on an unprecedented scale.  The access to data, driven in many cases by changes to regulation, is empowering consumers more than ever.   Callcredit is at the forefront of development within this second digital revolution.  

We’re excited to join FDATA and work alongside member companies to help consumers make better financial decisions, and empower them to tame the increasingly daunting task of managing all their personal data.

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Another four start-ups join FDATA

The Financial Data and Technology Association has announced another four new start-ups have joined its growing membership ahead of the formal commencement of the Implementation Entity’s work on delivering an API.

The companies – Castlight Financial, PayLink, RentData and Truelayer – provide innovative financial applications and services to empower customers to make better decisions

FDATA’s members are united by a desire to see a quality API implemented in as fast a timescale as possible, encompassing as much financial data as possible, and the Association is committed to helping the Implementation Entity achieve this.

Andy Maciver, FDATA’s Executive Director, said:

“FDATA’s membership has now doubled since the summer. We believe we are the premier Association to represent the needs of the fintech sector as we navigate what could be a game-changer for the way the consumers of the UK manage their data and their money.

“We must get it right, and FDATA is there to ensure that we do.

“Our four new members – all innovative start-ups pushing forward exciting business plans – will help ensure that as an Association we represent all views and, crucially, interrogate all proposals to ensure that they are in the best interests of the consumer.”

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