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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.

Download: FDATA submission response to CMAs Retail banking market investigation – Provisional decision on remedies – 7.6.2016

The Financial Data and Technology Association (FDATA) has today responded to the CMA’s provisional decision on remedies, the penultimate stage of its retail banking market investigation.

FDATA’s full response can be read here.

Commenting, FDATA’s Executive Director Andy Maciver said:

“FDATA has given a broad and strong endorsement to the CMA for its provisional remedies. We particularly welcome the provisional decision to require our largest banks to make transaction data available through an API, and the decision to pull forward by one year the write-access timetable suggested in the Open Banking Standard.

“FDATA has campaigned on the basis of four remaining concerns during this first half of 2016; those of the timescale for implementation, the scope of data to be included in the API, the role of screen-scraping and the problem of redacting data.

“We consider the CMA’s report to be a big step in the right direction on these issues and we believe that the CMA is determined to reach a destination which meets consumer demand. This is most welcome.

“However we have made several recommendations in our response which we believe would further improve the outcome and meet the aims of the CMA in terms of market impact, and we look forward to working with the CMA and other stakeholders on these recommendations between now and August.”

ENDS

Download: FDATA submission response to CMAs Retail banking market investigation – Provisional decision on remedies – 7.6.2016

FDATA and techUK has announced the outline agenda for the discussion on APIs to be held in London on 23rd March. It is as follows:

Event Host: Keith Saxton, Chairman of techUK

Event Chair: Gavin Littlejohn, Chairman of FDATA

09.00 Registration and coffee

09.30 Opening remarks from Keith Saxton

09.45 Opening remarks from Gavin Littlejohn

10.00 Panel 1: APIs – Further and faster? (Panel chair: Dan Morgan, Innovate Finance)

10.45 Use case demonstrations – Round 1

11.20 Coffee

11.30 Panel 2: APIs – Open vs closed (Panel chair: John Midgley, Intuit)

12.15 Use case demonstrations – Round 2

12.50 Closing remarks from Chair

13.00 Lunch and networking

14.00 Close

Please contact either oisin.merrins@techuk.org or [email protected].uk for more information.

OBWG – The Open Banking Standard

• But industry body says rollout of data into API can be wider and much faster
  

HM Treasury has today published the report of the Open Banking Working Group (OBWG), which it commissioned last August to develop a detailed framework for the design of an open API.

FDATA Executive Director Andy Maciver was a member of the OBWG Steering Group, and FDATA members sat on all six of the sub-groups it created to develop the detailed proposals.

Commenting on the release of the report, Andy Maciver said:

“We were delighted to be involved in this report, the production of which brought together all of the industries required to make open banking a success, including banks, regulators and financial technology bodies.

“We welcome the proposed framework which has been developed – the suggestions for how we operate standards, security and governance are robust and represent a solid foundation on which to build.

“We are also pleased that the banking industry felt able to sign up to a report which makes clear that the passing of data to authorised third parties on behalf of consumers, in order to help them make better financial decisions, is both possible and desirable.

“However, we would restate what we have campaigned on throughout the process; if the UK really is to develop any form of competitive advantage, and be seen as a leader in this field, then we must travel further and faster.

“The recommendation of the report, that some read-only data be available through an API from Q1 2017, with more being available from Q1 2018, and write-access from Q1 2019, effectively copies the timescales required by PSD2.

“We believe that all of a consumer’s financial data across all types of account should be available in an API far more quickly than this, and the technology already exists to make it happen.

“Third party providers of account aggregation and payment initiation services exist because consumers have demanded it. Consumers want a smooth and sophisticated way to analyse and manage their financial lives. They want their financial data – all of it, unredacted and in real time – in one place. Our members provide that for them, and the slower this process is, the longer it will take for the UK to allow its consumers to access the services they want and need.”

Financial Data and Technology Association’s submission to the HMT outlines options for data aggregation industry

The Financial Data and Technology Association (FDATA), the industry body for financial technology (fintech) companies which give consumers more control over their financial data, has submitted evidence to HM Treasury on its call for evidence on data sharing and open data in banking.

FDATA’s members – six of the leading companies in the industry – use security credentials shared by the user to aggregate their financial life in one place. Our members’ services include:

• aggregating savings and debts to create a holistic analysis of a consumer’s financial situation
• analysing whether it is more efficient to save or to pay off credit
• checking whether the savings or lending rate on a product can be bettered elsewhere

Welcoming the Treasury’s general approach on the issue, FDATA made the following points, amongst others, in its submission:

• the market for financial data aggregation is far more open and advanced in other countries, notably the US, than it is here in the UK
• the industry would benefit from the addition of standard and non-standard APIs to the market, in addition to the currently well-used screen-scraping technology
• financial institutions, technical providers and data aggregators need to agree with government and regulators a set of minimum industry standards for operating as an aggregator in an open data era

The full submission can be read here.

Commenting, FDATA director Andy Maciver said:

“Our members provide an incredibly valuable service to the personal and small business markets, allowing them to manage all their accounts, of different types and with different providers, in one place.

“It is a testament to the services our members provide that they have built a large customer base despite the environment for open data not yet being a friendly one. Ensuring that this market can operate to the fullest of its ability will provide an environment for a revolution in money management.

“The era of openness in financial data must now be ushered in. We want consumers to benefit from our members’ services and we want to be at the centre of a thriving new British fintech industry legitimised and underpinned by strict standards of practice.”

FDATA submission response to HMTs call for evidence on data sharing and open data in banking – 25.2.2015