Dear Commission Members,
dear MEPs and
dear Members of the European Council,
Dealing with all pros and cons of the debate on the EBA’s Regulatory Technical Standards (RTS) under PSD2 and especially with the “Screen Scraping” fronts must indeed be a challenge. As it comes with far more than the usual number of hurdles. That is, most importantly: regulating fast-evolving technology. None of us involved can provide solid experience in that regard.
This open letter is not about the usual pros and cons of this debate. Others have summarised them well. It rather intends to provide you with actual solutions, i.e. smart trade-off ideas that could mean an end to the everlasting “Screen Scraping Debate” and eventually the RTS process. From our point of view, every decision you make on this topic over the next weeks should be challenged by means of the following questions, in addition to PSD2’s general goals or first level regulation limits. (more…)