The EACB welcomes the opportunity to participate in the EBA consultation on the draft Guidelines on the criteria on how to stipulate the minimum monetary amount of the professional indemnity insurance or other comparable guarantee under Article 5(4) of Directive (EU) 2015/2366.
The EACB believes that the introduction of third party payment providers clearly must be done in a fair, secure, scalable and non-fragmented way. This, together with the allocation of liabilities emerging from PSD2 and the fact that Account Servicing Payment Service Providers are the first port of call for problems that arise, gives particular importance to the question of how to calculate the minimum amount of the professional indemnity insurance of TPPs.