Entries by Dr. Susanne Grohé

Opinion on the draft EBA guidelines on loan origination and monitoring: Please accept technology as part of banking!

The European Banking Authority (EBA) has carried out a consultation on draft guidelines on loan origination and monitoring. These guidelines reduce the role of technology to something that needs to be monitored and present it as inferior to traditional processes. Furthermore, the guidelines on loan origination appear to emphasise traditional methods of data collection and […]

Is Libra e-money?

Is Libra e-money or rather a virtual currency? Since Libra is based on blockchain technology, it would stand to reason that Libra is a cryptocurrency. However, the underlying technology is not relevant for the regulatory classification. From a European point of view, there are two possible categories for Libra: e-money (as defined in EMD2) or […]

The Libra cryptocurrency – a simple explanation

…also for people who have so far not looked into blockchain… What is the Libra cryptocurrency? Facebook has announced, in conjunction with other companies, that it will issue its own Libra cryptocurrency. It is remarkable that so many very large companies, some of which are competitors, have joined forces to do this. Their aim is […]

EBA clarification: Setting up a SEPA direct debit mandate does not require strong customer authentication

After the European Banking Authority (EBA) sparked considerable excitement with one of its answers given in the Q&A tool (see my article on the possibly dim future of online SEPA direct debit payments, and the BaFin had already published a statement (see “Strong customer authentication for online SEPA direct debit payments”), the EBA clarification has […]

Strong customer authentication for online SEPA direct debits: BaFin’s clarification

You shall never ask me? But questions are useful as sometimes answers are indeed given… In one of my last posts I dealt with the problematic EBA response concerning strong customer authentication for online SEPA direct debit payments. The EBA had stated that when setting up an online SEPA mandate strong customer authentication was required. […]

PayTechTalk 37 – Approval procedures: directors, qualifying holdings, and capital requirements

In our 34th episode of PayTechTalk I talked with my colleague Christian about the licence types for payment service providers. Upon hearing this podcast, Marko Wenthin, one of the co-founders of SolarisBank, asked us to talk in more detail about application for authorization and in particular about directors, qualifying holdings,  and capital requirements, as it […]

What is a Security Token Offering (STO)?

The hype surrounding ICOs has cooled down a bit of late, but now Germany is seeing its first Security Token Offering from Bitbond Finance GmbH. What is behind it? How is it different to an ICO? In order to answer these and other questions, let’s take a closer look at the topic. A Security Token […]

You shall never ask me (Nie sollst Du mich befragen) – the possibly dim future of online SEPA direct debit payments

A new response by the EBA in their Q&A tool may have a huge impact on the future of online SEPA direct debit payments. When asked if strong customer authentication (SCA) has to be applied to the electronic processing of online SEPA direct debit payments, the EBA responded that the setting up of such a […]

Screen Scraping is dead – long live Screen Scraping!

A heated debate has been going on for years as to whether account information services providers (AISP) and payment initiation services providers (PISP) and card based payment instrument issuers (CBPII) may use screen scraping as a means of accessing the payment user’s account at their payment account service provider (ASPSP). With PSD2 and more specifically, […]

Who am I? Identity management and strong customer authentication

Identity management and strong customer authentication are the talk of the day. However, the terminology is more than confusing. For example, customers need to be identified for the purposes of AML, they need to authorize a payment, and when authenticating themselves, it is checked whether they are actually the person they pretend to be. I […]