Excursus – My dear PSD2, it’s been almost a year …
My dear PSD2 …
… it’s been almost a year since you stepped into our lives. We fell in love with you at first sight. You were the answer to our hopes for innovation in open banking, consumer freedom and for our legally watertight business models in what was once a rather uncertain area. We were attracted by your EU level-playing-field character, your empathy for fintech use cases and your potential for fostering collaboration between banking incumbents and new market players.
Like in every good relationship your flaws have shown through the more time we have spent together.
You have troubled us with some of your details on the one hand and your lack of clarification on the other hand. You have challenged us with your already outdated scope, even without being implemented yet. You have annoyed us with the consequences resulting from the patchwork of official bodies responsible for your realisation. Your specifics have frequently provoked new mistrust and controversies between the old world of banks and the new spirit of banking. You have become proof positive that regulating fintech is tricky. So in getting to know you and understanding you in detail, we have had our ups and downs.
Relationships always require a lot of work and a lot of communication – but also to bite one’s tongue sometimes
After the first phase of enthusiasm, we have realised PSD2 means a lot of work for us. This includes:
- PSD2 vs. market practice: keeping track of and providing content to all relevant consultations by EU as well as national legislative and regulatory/supervisory bodies – on our own behalf or as part of industry working groups.
- Setting limits and cooperating: laboriously finding out about PSD2’s limits and the subset of market needs for which bilateral amendments should be prepared.
- Knowledge spread: coping with the diverse levels of expert knowledge concerning PSD2 and its market practice when talking to our business partners or officials.
- Information overload vs. actual know-how: staying open to new ideas from constructive discussions and sorting the wheat from the chaff when faced with the recent mass of publications, studies and simple tweets.
- Positive thinking: upholding one’s positive mindset in times of market frustration, i.e. trying to “stay away from negative people, as they have a problem for every solution”.
- Compliance: having to prepare our internal organisation for compliance with PSD2 and according standards and guidelines without knowing what the final requirements will actually look like.
- And at the same time: freedom vs. structure, i.e. keeping our startup spirit alive and maintaining our agile API development processes as well as our highly flexible business development and team structures while developing required structures.
So to actually benefit from PSD2’s opportunities, some compromises have to be made. A subset of them is quite painful.
So before 2016 is over, let’s take a step back and wonder …
… are the days of seeing PSD2 through rose-coloured glasses over today?
Not yet. We are still in love with you and looking forward to going the next joint steps! Because you are the young and still-inexperienced version of a useful regulation for the European banking future. If legislative and regulatory/supervisory bodies, which are currently working on your detailed implementation, recognize the need to become more and more agile themselves, there is hope that we will live happily ever after. Well, at least until we cannot hide our appreciation for a younger, more agile and leaner “EU Regulation on Banking’s Future” any longer. But for now, let’s have a happy new year, PSD2. ♥