EMA response to Consultation on APP Fraud CRM

“The issues raised in this response have significant competition and policy implications for our members. Implementation of the code in its current form could in our view lead to multiple failures of smaller PSPs, who would either be unable to compete with larger PSPs with more diverse sources of income, or be the subject of multiple fraud related compensation claims – over which they have no control, and which they cannot support. To this end, we counsel against extending the code beyond the meeting of a reasonable duty of care, and against a subjective definition of vulnerability. It is better to achieve a significant but incomplete protective environment for users than to seek to protect users perfectly and in doing so degrade the product offerings, increase costs for users and decrease choice.”